20111111 UBC Reminder Proposed Policy Amendment: Policy #97

CALL FOR COMMENTS – PROPOSED POLICY AMENDMENT: POLICY #97 (Conflict of Interest and Conflict of Commitment)

A reminder that the UBC community is invited to comment on proposed amendments to the Conflict of Interest and Conflict of Commitment policy.

The deadline for comments is November 25, 2011. Please submit feedback to the Conflict of Interest Administrator at the Office of the University Counsel at conflict.of.interest@ubc.ca . A copy of the proposed policy is attached to this e-mail and details of the proposed changes are below.

The Board of Governors adopted Policy #97 in September 1992 and approved a significant overhaul of Policy #97 in March 2005. The University Counsel reviewed the status of Policy #97 against the requirements of funding agencies including the Tri-Council Policy Statement: Ethical Conduct for Research Involving Humans, revised in December 2010. The University Counsel also receives regular reports on compliance issues from UBC’s Conflict of Interest Committee.

Key elements of the proposed Policy are:

– Background and Purposes and Section 2.2 contain general statements that put the Revised Policy into its larger context. The context statements emphasize the importance of identifying, disclosing, and managing conflicts and the impact that a failure to do so may have on UBC and UBC Persons.

– The Review Committee proposes to add whistleblower provisions to the Revised Policy and addresses UBC’s Conflict of Interest Committee’s role under the new whistleblower provisions Conflict of Commitment Provisions

1. Explicitly address conflicts of commitment arising from faculty members enrolling in a degree, diploma or certificate program at UBC or any other educational institution. Note, this issue results from the decision to repeal Policy #46 “Full-Time Members of Faculty as Degree Candidates”.

2. Expand the definition of “Outside Professional Activities” to include external teaching, external academic appointments and external speaking engagements.

Conflict of Interest Provisions

3. Clarify the definition of a Conflict of Interest and expressly set out the two types of conflicts-actual and potential. As well, specific references have been made to the concept of perceived conflict of interest throughout the Revised Policy.

4. Increase the monetary limit of gifts to $500, which matches the Canada Revenue Agency’s threshold for gifts, and clarify the circumstances in which a gift may create a conflict of interest.

5. Explicitly capture circumstances where personal considerations (an intentionally broad term) compromise professional judgment in conducting or reporting research, teaching, or carrying out administrative activities.

6. Give guidance about the process to be followed if the Initial Reviewer himself or herself is party to a conflict of interest with the UBC Person making the disclosure.

7. Clarify that a person has a Financial Interest when the person (i) actually has something of a certain value; or (ii) has the expectation to receive something of a certain value.

8. Lower the monetary amount necessary for an interest to qualify as a “Financial Interest”, from $10,000 to $5,000.

9. Change the measurement from $5,000 per annum, to $5,000 in any one calendar year. Procedures

10. Clarify who must file annual disclosures, namely: any UBC Person who is a faculty member or who has signing authority over an active account that is used for a research purpose.

11. Confirm the established practice that all annual disclosures are to be submitted via the Researcher Information Service (RISe) system.