Conflicts of interest in research

A conflict of interest (COI) arises in situations in which financial or other personal considerations have the potential to compromise or bias professional judgment and objectivity. Conflicts of interest are not unusual in a modern academic setting but must be addressed in order to provide transparency and protect research integrity. The COI in Research Program administers activities related to reporting, assessing, and managing financial and non-financial interests for the university research enterprise. 

RAMS-AIRS

The Activity and Interest Reporting System (AIRS) is an electronic Research Administration Management System (RAMS) for the reporting of interests pertaining to research. 'COI Investigators', designated by the PI as having responsibility and independence in the design, conduct, and reporting of research, report interests in their Financial Interest Report (FIR).

• Access the AIRS
• AIRS how-to guide
• How to complete the annual FIR update
• Who is a 'COI Investigator' for AIRS reporting purposes?
• What interests do I report?
• Additional AIRS guidance and training

How to complete your annual FIR update

A quick guide to AIRS and your financial interest report (FIR)
Log in to AIRS starting on May 10^th

Policies

• VCU policy: Conflicts of interest in research
• VCU policy: Institutional conflicts of interest in research
• VCU policy: Research and development exception for the Virginia Conflict of Interests Act

Regulations

Federal regulations

• PHS: Promoting Objectivity in Research (42 C.F.R. Part 50, Subpart F)
• NSF: Conflict of Interest Policies (GPM 510)
• FDA: Financial Disclosure by Clinical Investigators (Title 21 Part 54)

State law

• State and Local Government Conflict of Interests Act: Prohibited contracts by officers and employees of state government (2.2-3106)

Guidance

Internal guidance

• What interests do I report?
• COI considerations for start-ups
• Potential management scenarios for COI determinations
• IRB conflict of interest requirements

External guidance

• FDA: Guidance for clinical investigators, industry, and FDA staff - financial disclosure by clinical investigators
• ORI: Conflicts of interest and commitment
• ICMJE: Author responsibilities – conflicts of interest

Conflict of interest committee

The Conflict of Interest in Research Committee (COIC) is a standing committee of the university, composed of faculty, administrative personnel, and ex-officio members, convened under the authority of the vice president for research and innovation. The COIC is charged to evaluate investigator reports of research-related financial and non-financial interests and to determine an appropriate resolution, including the development of a management strategy, as appropriate. Committee members are required to adhere to applicable rules of privacy and confidentiality pertaining to conflict of interest review. The COIC members are:

• Gretchen Brophy, Pharm.D., BCPS, FCCP, FCCM - School of Pharmacy, Department of Pharmacotherapy & Outcomes Science;  School of Medicine, Department of Neurosurgery
• Alan Dow, M.D., MSHA - School of Medicine, Department of Internal Medicine, Division of Hospital Medicine; Asst vice president of Health Sciences for Interprofessional Education and Collaborative Care
• Robert Klenke, Ph.D. - College of Engineering, Department of Electrical and Computer Engineering
• Joyce Lloyd, Ph.D. - School of Medicine, Department of Human and Molecular Genetics;  Associate dean, VCU Graduate School
• Caley Dugan, MHA - COIC Chair; Director, Office of Research Integrity and Ethics
• Jason Reed, Ph.D. - College of Humanities and Sciences, Department of Physics
  
• Richard Sterling, M.D. - School of Medicine, Department of Internal Medicine, Division of Gastroenterology, Hepatology, and Nutrition