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Conflict of Interest in Research

Dartmouth's Conflict of Interest Policy

Financial Conflict of Interest (FCOI) regulations: Dartmouth has an obligation under federal law and institutional policy, as well as an ethical duty, to assure that the design, conduct and reporting of Research will not be biased by any conflicting interests of an Investigator. The objectivity of research is of paramount importance and the basis for obtaining and maintaining public trust.  Financial Conflict of Interest regulations related to federally funded research address the increasing complexities of financial interests held by researchers in all areas, and the resulting interactions among Government, research Institutions, and the private sector.

Disclosure Requirements: Before a proposal for research funding is made to a funding agency, federal (NIH & NSF) regulations require each person responsible for the design, conduct or reporting of research sponsored by these agencies to disclose any significant financial interests (PI and Senior Key Personnel). Dartmouth College policy applies this standard to all externally funded research. Federal Regulations and Dartmouth policy also require that research involving Human Subjects is reviewed for financial conflicts of interest.

The Office of Research Integrity in the Office of the Vice Provost for Research oversees all research related Conflict of Interest disclosures, conducts reviews and works with Dartmouth’s Conflict of Interest Committee to address and manage conflict of interests related to research. If a Financial Conflict of Interest is found by the Conflict of Interest Committee, it does not mean the proposed research cannot go forward. In most cases the conflict can be addressed through a conflict of interest management plan. If you have questions related to Research Conflict of Interest, please email rcoi@Dartmouth.edu or contact Henrike Frowein Henrike.Frowein@Dartmouth.edu 603 646 0239. For questions related to the online disclosure system please contact nicole.h.hewett@dartmouth.edu or call 603 646 0703.

If you intend to apply for sponsored research funds through the Office of Sponsored Projects (OSP), please visit Rapport.Dartmouth.edu to submit your Annual COI Disclosure through the online system. You will find additional detailed information on the disclosure requirements in the system, which you can access the here. A Dartmouth NetID account is needed to submit a COI disclosure. For researchers who don’t have access to a Dartmouth NetID account, a sponsored account can be established. Read about Sponsored Accounts and download a request form here.  If you have questions about a Dartmouth NetID or other access issues, please contact the Dartmouth College Help Desk or call 603-646-2999. (The Geisel School of Medicine researchers contact Geisel Computing Support or call 603-650-1600.) 

Non Research Related Conflict of Interest: You may be asked to report other financial interests in relation to your non-research professional responsibilities (e.g. in relation to DHMC clinical duties or continuing medical education). Currently, these processes are separate from the research compliance disclosure and review process at Dartmouth. Reporting interests related to sponsored research does not eliminate or substitute for other institutional processes related to financial interests including disclosures to DHMC for clinical or other duties.

Mandatory PHS COI Education:

It is required by Federal Regulation that all researchers (PIs and Senior Key Personnel) complete COI training prior to engaging in PHS funded research and at least every four years. Training must be completed immediately under the designated circumstances:

  • Institutional Financial Conflict of Interest policies change in a manner that affects Investigator requirements
  • An Investigator is new to an Institution
  • An Institution finds that an Investigator is not in compliance with the Institution’s Financial Conflict of Interest policy or management plan.

Dartmouth offers COI training online through the Collaborative Institutional Training Initiative (CITI) program. Read more about this option.  The following modules are available:

  • The Conflict of Interest Mini-Course, which consists of two brief on line training modules.
  • The COI refresher module once re-training is required after four years.

 

Public Access Requests

Federal regulations require that reportable information on financial conflicts of interest related to a PHS funded research project is made available to the public upon request. Such requests may be submitted via the Office of Research Integrity website. Please do not respond directly to requests for information. Forward requests to rcoi@dartmouth.edu  or directly to the Office of Research Integrity.

Travel Disclosure Requirements for PHS-Funded Investigators

 

Questions/Help

Any questions concerning COI disclosures in relation to awards or proposals or disclosures required for grant applications please contact your OSP Grants Officer or sponsored.projects@dartmouth.edu or your Department Research Administrator.

Questions concerning logging in or using the system should be directed to rcoi@dartmouth.edu.

Any questions about the Conflict of Interest policy or review process should be directed to rcoi@dartmouth.edu or the Research Compliance Office directly.

 

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