TEXAS AGRILIFE REESEARCH PROCEDURES

Approved: November 4, 1998
Supplements: System Policy 15.01, System Regulation 15.01.03, and Research Rule 15.01.03.A1.

The procedures contained herein are designed to aid employees in their consideration of any potential conflict of interest during all phases of sponsored research and educational activities. These procedures supplement System Regulation 15.01.03, Conflict of Interest in the Design, Conduct and Reporting of Sponsored Research and Educational Activities, and AgriLife Research Rule 15.01.03.A1, Conflict of Interest in the Design, Conduct and Reporting of Sponsored Research and Educational Activities.

2.01 Disclosure of Financial Interest(s)

A. All pertinent Significant Financial Interests must be disclosed at the time a proposal is submitted for approval. The investigator's Texas Agrilife Research (AgriLife Research) Form 215-96, Significant Financial Interest Disclosure, shall be delivered to the Office of Research Administration in a sealed envelope marked "confidential." This information shall be updated by the investigator if any significant financial interests are obtained during the pre-award period.

1. If a potential conflict of interest exists, the investigator is required to disclose the information as listed in System Regulation 15.01.03, Conflict of Interest in the Design, Conduct, and Reporting of Sponsored Research and Educational Activities, paragraph 3.1, about any entity which would reasonably appear to have a financial interest that would be directly and significantly affected by the research funded or proposed to be funded.

2. Each investigator shall also complete a separate AgriLife Research Form 215-96, Significant Financial Interest Disclosure, as applicable, for his/her spouse and dependent children and include all required supporting documentation at the time the proposal is submitted for approval.

B. Subgrantees, contractors, or collaborators included in proposals submitted by the Research shall certify that their organization has a Conflict of Interest Policy in compliance with the Federal regulations prior to the submission of the proposal unless they are exempted from the federal requirement.

C. Questions regarding specific potential conflict of interest situations may be clarified by consulting with the Director, the Assistant Vice Chancellor for Administration, the Manager of Research Administration, or the Assistant Director for Human Resources.

2.02 Review of Disclosure

A. Upon notification of an approved award, the Director, the Assistant Vice Chancellor for Administration, or the Manager of Research Administration shall conduct an initial review of all financial disclosure information to determine if any disclosed significant financial interest could affect the design, conduct, or reporting of the proposed sponsored project. If the initial determination is made that there may be a potential conflict of interest, the investigator will be notified and the disclosure packet will be reviewed by AgriLife Research Conflict of Interest Review Panel, consisting of the Director, the Assistant Vice Chancellor for Administration, and the Manager of Research Administration.

B. The AgriLife Research Conflict of Interest Review Panel shall perform all the functions of the Conflict of Interest Review Committee (CIRC) as outlined in System Regulation 15.01.03, Conflict of Interest in the Design, Conduct, and Reporting of Sponsored Research and Educational Activities.

C. Annual updates must be submitted during the life of the project by August 31 of each year by filing a supplemental disclosure form with the Director through the Office of Research Administration.

2.03 Appeal

A. If the Conflict of Interest Review Panel determines that an unresolvable conflict of interest exists and disapproves the proposal or acceptance of an award and the investigator believes the relevant information is being misinterpreted or misunderstood in relation to the proposed award, the investigator may request that the Director appoint an ad hoc committee to review the information and provide a recommendation for action.

B. The Director, at his/her discretion, may appoint an ad hoc review committee composed of individuals from inside and outside AgriLife Research to review the relevant information and provide a recommendation on the investigator's appeal. The ad hoc committee's recommendation may be accepted or rejected by the Director. The investigator will be informed of this decision by the Director. All unresolved conflicts will be immediately reported to the funding agency or agencies.

2.04 Record Keeping

Records of investigator financial disclosures and of actions taken to manage actual or potential conflicts of interest shall be retained by Research Administration Office until three (3) years after the termination or completion of the award to which they are related, or the resolution of any government action involving these records.

2.05 Enforcement

A. Apparent oversights or violations shall be brought to the attention of the investigator, who will be afforded an opportunity to comply. The investigator shall present the proposed correction to the AgriLife Research Conflict of Interest Review Panel for review and action within thirty (30) calendar days of the notification through normal administrative channels. Failure to comply will constitute an intentional violation, as discussed in System Regulation 15.01.03, Conflict of Interest in the Design, Conduct, and Reporting of Sponsored Research and Educational Activities, paragraph 3.4.2.

B. Cases that involve investigators affiliated with AgriLife Research and that include the possibility of scientific misconduct shall be processed in a manner consistent with System Regulation 15.99.03, Ethics in Research and Scholarship.

C. Cases that involve investigators not affiliated with AgriLife Research and that include the possibility of scientific misconduct shall be processed and appealed in a manner consistent with their home institution's or organization's policies and procedures.