Related Conflict of Interest Policies

Title : Research Financial Conflict of Interest Relating to PHS Grants, Cooperative Agreements and Contracts updated value of a previously disclosed equity interest). d) Each Investigator who is planning to participate in the Research will submit an annual disclosure form and will disclose to the COI Official the Investigator's SFIs no later than the time of application for Research; and comply with the instructions and directives (e.g., training and conflict of interest management plan) of the COI Official with regard to this policy. C. Appeal 1. The Investigator may contest the determination of a Financial Conflict of Interest and may appeal any conditions of the management plan to the COIC. The COIC will have final decision-making authority in such cases. D. Records 1. BH will maintain the online COI Disclosure and other records of all financial disclosures and all actions taken by BH with respect to each FCOI for at least three years from the date of submission of the final expenditures report or, where applicable, from other dates specified in 45 CFR 75.361-365 for different situations.. a) For contracts, such retention shall be for three years after final payment or, where applicable, for the other time periods specified in 48 CFR Part 4, Subpart 4.7 (See 4.7 through 4.706). 2. Records will be maintained by the COI Official and disclosure completion dates will be shared with the Sponsored Projects Office. All disclosures and related documentation are considered, within BH, to be confidential to the extent permitted by applicable law but see Article IV.E (below). E. Federal Agencies and Financial Interest Information 1. The information disclosed by an Investigator may be released to the funding agency representatives. HHS has asserted (in 42 CFR 50, Subpart F and 45 CFR Part 94) that HHS will maintain the confidentiality of all records of Financial Interests to the extent permitted by law. F. Reporting 1. Prior to BH’s expenditure of any funds under a PHS-funded Research project, BH shall provide to the PHS Awarding Component an FCOI report regarding any Investigator’s SFI found by BH to be conflicting (i.e., a FCOI) and ensure that BH has implemented a management plan in accordance with this policy and the regulations. In cases in which BH identifies a FCOI and eliminates it prior to the expenditure of PHS-awarded funds, BH shall not submit an FCOI report to the PHS Awarding Component. 2. For any SFI that the COI Official identifies as conflicting subsequent to the BH's initial FCOI report during an ongoing Research project (e.g., upon the participation of an Investigator who is new to the Research project), the COI Official shall provide to the PHS Awarding Component, within sixty days, an FCOI report regarding the FCOI and ensure that BH has implemented a management plan in accordance with this policy. Where such FCOI report involves a SFI that was not disclosed timely by an Investigator or, for whatever reason, was not previously reviewed or managed by BH (e.g., was not timely reviewed or reported by a subrecipient), the COI Official also is required to complete a retrospective review to determine whether any Research, or portion thereof, conducted prior to the identification and management of the FCOI was biased in the design, conduct, or reporting of such Research. Additionally, if bias is found, the COI Official is required to notify the PHS Awarding Component promptly and submit a mitigation report to the PHS Awarding Component.

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