Management Procedures
The College has implemented a new Conflict of Interest Management Procedure to ensure a fair and equitable review process. A COI disclosure form is automatically approved if the disclosure does not list any relationships. Otherwise, the disclosure form routes to a series of reviewers, depending on if the reviewer determines an outside interest or relationship to be a conflict, which may require a management plan. The process is outlined below.
Note: See the Roles and Responsibilities table to identify your role.
Step 1: If the Disclosee submits a form with a disclosed actual or potiential outside interest or relationship, the form will be routed for review.
Step 2: The Disclosee’s Area Designee, also known as the Chair or Supervisor, will receive the routed COI for an initial review. If a conflict is identified, the Chair or Supervisor will route the COI to a Compliance Officer, a staff member in the General Counsel office who works with the Office of Sponsored Programs during the COI annual campaign period.
Step 3: Compliance Officer will review the COI form and convene a COI Committee meeting, at which time the disclosure will be assigned to a committee member for further review.
Step 4: COI Committee reviewer will review the potential conflict(s) and draft a management plan and send it to the Compliance Officer for review.
Step 5: Compliance Officer will review the management plan. Once it is approved, the Compliance Officer will send it to the disclosee’s Chair or Supervisor for review and approval.
Step 6: Chair or Supervisor will review the management plan, and if approved, will send the management plan to the Disclosee.
Step 7: Disclosee will review and sign the management plan, and will send it to the Compliance Officer.
Step 8: Compliance Officer will attach the management plan to the Cayuse COI record and route the complete COI record to the VP or assigned designee for a final review.
Step 9: VP or Designee routes the approved COI record to the Compliance Officer.
Step 10: Compliance Officer updates the Cayuse record to reflect that a conflict has been determined and managed (or unmanageable).
Roles and Responsibilities
|
Role |
Responsibility |
|
Disclosee |
Each faculty and staff member is required to submit a disclosure and is responsible for disclosing all relevant outside interests and relationships as defined in Teachers College Conflict of Interest and Commitment Policy. |
|
Area Designee |
A COI reviewer who is a department chair, supervisor or other leadership-level position within a unit and is responsible for the initial review of any potential conflicts disclosed by faculty or staff in their reporting line. |
|
Compliance Officer |
The Compliance Officer oversees the COI disclosure process at Teachers College, convenes the COI committee to review disclosures and create management plan as necessary, and ensuresthat management plans are foll owed. |
|
Conflict of Interest Committee (COIC) |
The COI committee includes the Vice Dean for Research, Compliance Officer and representatives from Administration, General Counsel, Faculty Affairs and Ad Hoc reviewers for subject matter expertise. This group is responsible for drafting management plans when conflicts arise due to relationships disclosed by faculty or staff members. |
|
Reviewers |
Depending on the conflict identified, several layers of reviewers can exist including the Area Designee, Compliance Officer and COI Committee. All COIs will be reviewed by the Area Designee, unless no conflicts are listed in the disclosure, at which point the process will end and not be reviewed. |