What do Researchers need to know about HHS’ new Public Health Service (PHS) Sponsored Research Financial Conflict of Interest Policy?
Who does this policy apply to?
This policy applies only to Investigators who conduct Public Health Service (PHS)-sponsored research at Hamilton Health Sciences.
What do I need to do if I conduct Public Health Service (PHS) sponsored research?
All PHS-sponsored Investigators are required to disclose their significant financial interests to the Research Administration office on an annual and ad hoc basis.
What do I need to disclose?
You are required to disclose your significant financial interests that reasonably appear to be related to your institutional responsibilities, such as:
- Salary or other payments for services (including consulting fees, honoraria, or paid authorships).
- Any equity interests (including stocks or other ownership interests).
- Intellectual property rights (including patents, trademarks and copyrights), upon receipt of royalties related to such rights.
- Any reimbursed or sponsored travel related to your Institutional responsibilities. This includes travel that is paid on behalf of the Investigator as well as travel that is reimbursed, even if the exact monetary value is not readily available, and excludes travel sponsored by U.S. Federal, state or local governmental agencies.
You do not have to disclose:
- Salary, royalties, or other remuneration from Hamilton Health Sciences.
- Income from the authorship of academic works.
- Income from engagements sponsored by U.S. governmental agencies or fellow academic centres.
- Equity interests or income from investments such as mutual funds and retirement accounts, so long as you do not directly control the investment decisions made in these funds/accounts.
What constitutes a Financial Conflict of Interest?
Financial Conflict of Interest means a Significant Financial Interest that Hamilton Health Sciences believes could significantly affect the design, conduct or reporting of PHS-sponsored research.
Who determines if what I’ve disclosed is a Significant Financial Interest?
The Director of Research Administration makes this determination
How do I know if I have a Significant Financial Interest?
Significant Financial Interest is related to your institutional responsibilities AND:
- if with a publicly traded entity, the value of any salary or other payments or equity interest held is more than $5,000.00.
- if with a non-publicly traded entity, the value of any salary or other payments for services is more than $5,000.00.
- if with a non-publicly-traded company, is an equity interest of any value during.
- is income exceeding $5,000.00 related to intellectual property rights and interests not reimbursed through the Institution.
- is reimbursed or sponsored travel related to your institutional responsibilities.
What if I do have a Significant Financial Interest?
If there is a Financial Conflict of Interest that can be managed, the Director of Research Administration will develop and implement a written management plan. You will need to agree to and sign the written management plan before any related PHS-sponsored research goes forward.
What if I don’t comply with this policy?
Your related research activities could be suspended or other disciplinary actions may be taken until the matter is resolved.