Conflicts of Interest

NEW Conflict of Interest Policy

In fall 2023, after review and approval by key university stakeholders including the Faculty Senate's Professional Ethics and Academic Freedom Committee, the Board of Trustees approved the new Policy on Outside Interests, Relationships, and Professional Activities . Previously, the university had four unique population-specific conflict of interest and conflict of commitment policies. The Policy on Outside Interests, Relationships, and Professional Activities combined the population-specific policies, establishing general principles that apply to all GW Employees with subsequent role-specific addendums that outline expectations and requirements specific to university role. 

Conducting research with the highest scientific and ethical standards is critical in maintaining the public’s trust in the scientific process. GW policy establishes boundaries within which conflicts of interest are tolerable and beyond which they are intolerable; processes for review of actual and apparent conflicts of interest; and appropriate mechanisms for management of tolerable conflicts of interest.

GW Office of Research Integrity & Compliance (ORIC) collaborates with faculty, staff, internal GW offices, and external organizations to ensure quality review, management, and reporting of financial conflicts of interest and conflict of commitment related to research at GW University.

Important Points

• An up-to-date disclosure must be on file at ORIC for each Investigator on a proposal before the proposal can be submitted to the sponsor by the institution, and/or for each PI and Co-Investigator on an IRB protocol before a protocol can be approved by GW’s Institutional Review Board (IRB) or by an external IRB.
• Disclosure forms are analyzed by ORIC to determine if disclosed relationships are related to the disclosing individual’s research and/or administrative responsibilities.
• In addition to the annual review and reporting, ORIC also performs a project specific review or “transactional review” as proposals are reviewed before submission, and when grants are awarded to the institution (or preferably at “Just in Time” notification).
• ORIC manages COI in a manner compliant with sponsor’s COI policies, and those of sponsors, particularly those of federal agencies.
• Management plans are acknowledged by the individual, tracked over time, and monitored.
• Individuals are responsible for maintaining a current, accurate disclosure form with ORIC. Individuals must update their COI disclosure form within 30 calendar days of discovering, acquiring or establishing any new significant financial interests or changes in any existing significant financial interests that might reasonably be related to their GW responsibilities.

Federal regulations require that the University:

• Maintain a current, documented, and enforced COI policy
• Educate Investigators as to GW’s COI policies and procedures
• Facilitate and ensure Investigator compliance with initial and ongoing COI disclosure requirements
• Identify and manage COIs
• Flow down sponsor COI requirements to subrecipients/collaborators
• Meet sponsor and other COI reporting requirements

Who is Subject to Research COI Requirements?

Investigators, defined as any person, regardless of title or position, who is responsible for the design, conduct or reporting of research. This always includes:

Project Director / Principal Investigator

Anyone named as Key Personnel (by virtue of the definition of Key Personnel*)

Anyone listed as PI or Co-I of an IRB protocol

• This may also include:

Outside collaborators (e.g., subrecipient Investigators, consultants) who satisfy the definition of being responsible for the design, conduct, or reporting of the research

Any other faculty, staff, post-doctoral and clinical fellows, graduate students, or even technicians, who satisfy the definition of being independently responsible for the design, conduct, or reporting of the research

What Must Be Disclosed?

Significant Financial Interests held by an Investigator, or an Investigator’s Immediate Family Members, that is reasonably related to their GW responsibilities

Regulations, Policy and Resources

• GW Policy on Outside Interests, Relationships, and Professional Activities
• Public Health Service COI Regulation: Responsibility of Applicants for Promoting Objectivity in Research for which Public Health Service Funding is Sought and Responsible Prospective Contractors (PDF)
• Public Health Service COI FAQ: Frequently Asked Questions (FAQs) on the Responsibility of Applicants for Promoting Objectivity in Research (2011 Revised Regulations)
• Comparison of NEW Department of Energy COI requirements and PHS requirements