Conflict of Interest
Gulf of Mexico Research Initiative
Conflict of Interest Policy and Procedures
Approved December 13, 2012
The GoMRI Master Research Agreement references the expectation for management of Conflicts of Interest (COI) in Section 3 (Research Board), Section 4 (Consortia), Section 5 (Funding of Proposals), Section 7 (Grant Agreements), and Section 9 (Administrative Unit). The MRA references in several instances the standards followed by NSF in the development and execution of Conflicts of Interest practices; it is the intent of the Research Board to subscribe to those standards.
Section 3.2.1 states “the Research Board shall establish a conflict of interest policy and procedure to identify and manage, in a consistent and transparent manner, any potential or actual conflicts of interest involving Research Consortia and Research Investigators.”
GoMRI’s Conflict of Interest Policy and Procedures document is drawn from the experience and practices of National Academy of Science, the National Science Foundation and National Institute of Health. Below are the COI practices to be executed and associated documents used for each component of GoMRI as they relate to Section 3.2.1 of the MRA.
Research Board – Upon appointment to the Research Board each Board member must sign the Appendix 2 of the MRA “Research Board Conflict of Interest Policy and Confidentiality Statement” (Attachment 1) and complete the COI Disclosure Form (Attachment 2) to identify institutional, professional, and personal/financial conflicts. All forms are maintained by the Research Board Administrative Entity (AIBS) and the forms updated by the RB every 3 years. Any breach of COI will be brought to the attention of the RB leadership.
In the review of proposals, the Research Board must follow the GoMRI Programmatic Review Process (Attachment 3) which prescribes the preliminary identification of conflicts via the COI Disclosure Form. Each Board member is expected to announce other conflicts that become apparent before or during the review process. RB members are recused from discussion of individual proposals involving conflict. All RB members do participate in the final vote on the “package” of final projects identified for funding for a given competition.
Funding of Proposals – In the process of conducting proposal reviews each reviewer (email and panelist) must complete a Conflict of Interest Form (Attachment 4) and Nondisclosure Form (Attachment 5) prior to receiving proposals or participating in review panels. Furthermore they are instructed to identify any conflicts that become apparent during review. All forms are maintained by the Administrative Unit peer review unit (COL). Any breach of COI will be brought to the attention of the RB.
Consortia and Grant Agreements – As part of the contract execution each project Principle Investigator and Co-Investigators must fill out an Organizational Conflict of Interest/Personal Conflict of Interest Disclosure Form (Attachment 6). Forms for award recipients are maintained as part of the permanent grant record in GoMRI’s SharePoint. COI data are compiled in a spreadsheet for each competition and reviewed by the Grants Unit and CSO; findings of concern are brought to the attention of the RB chair.
Administrative Unit(s) – All administrative units have their own COI policies; Respective COI policy statements must be signed by all employees and include COL (Attachment 7) AIBS (Attachments 8 and 9) and GOMA (Attachment 10). Any breach of COI will be brought to the attention of the RB and Administrative Unit leadership.