Policy Process Overview

  • Complete an Annual Disclosure to report any outside interest or activities which may produce a conflicts of interest.

Throughout the year when conflicts of interest arise, complete a fresh form to:

  • Disclose new or significantly changed outside interests and activities for you to you or your Immediate Family which may influence your decision or behavior as to the Enterprise entity.
  • Disclose gifts/gratuities from same source in 1-month period with cumulative value $50 or more.
  • Disclose all corporate opportunities available to the discloser that could benefit the Enterprise.
  • Submit your Annual Disclosure forms via your supervisor (or Board/Committee/Chair) to the Chief Integrity Officer.
  • Chief Integrity Officer monitors compliance and investigates violations of this policy.
  • See specific definition of "conflicting interest" for a corporate board/committee member.
  • Submit conflict of interest disclosure form to the Board/Committee Chair or Director, or Chief Integrity Officer. Disclosures reviewed by Chief Executive Officers of Augusta University, Augusta University Medical Center, and Augusta University Medical Associates, Secretary of Augusta University, and Chief Integrity Officer. (But no one reviews his/her own disclosure form.)
  • After disclosure and discussion, discloser leaves the meeting and the conflict is considered and voted on. Remaining directors decide if conflict exists and address it, as follows: Chair may appoint a disinterested person or committee to investigate alternatives to the transaction/arrangement. With due diligence, the board/ committee will determine if the entity can reasonably obtain a more advantageous arrangement from another source and avoid a COI. If such an alternative is not possible, the board/committee will decide by vote if the transaction/arrangement is in the entity's best interest, for its benefit, fair and reasonable: and whether to enter into it.
  • Disclose your Significant Financial Interest (SFI) in relation to federally Sponsored Projects at the time you submit your proposal using the Proposal Disclosure form. DSPA will not submit your proposal until you have certified that all SFI's for any Investigators on the proposed project have been disclosed to the CIO. Update your disclosure within 30 days of a new SFI. Events triggering disclosure in research: 1) Initial proposal review; 2) Time of continuing review; and 3) Change in financial circumstances.
  • Also disclose reimbursed or sponsored travel (paid for the Investigator and not reimbursed to him/her by Augusta University) related to Institutional Responsibilities. Include purpose of trip, identity of sponsor/organizer, destination, duration, and determination or disclosure of monetary value, so the institution may determine if the travel constitutes a Financial Conflict of Interest with PHS-funded research. Exception: No disclosure required for travel reimbursed/sponsored by a federal, state or local government agency, institution of higher education defined at 20 U.S.C. 1001(a), an academic teaching hospital, medical center, or research institute affiliated w/ an institution of higher education.
  • Disclosure form(s) reviewed by Enterprise Conflict of Interest Panel convened by the CIO.
  • If disclosure is a Research COI, that is: a Significant Financial Interest related to the proposed Sponsored Project, then the Enterprise COI Panel will develop a Management Plan for the conflict.
  • Disclosures/Management Plans related to human subjects research will be shared with Augusta University's Institutional Review Board, which has final authority to approve/decline because of a Research COI.
  • Disclosure form(s) reviewed by Enterprise COI Panel convened by the Chief Integrity Officer.
  • The Conflict of Interest Panel works with the Covered Individual to develop an appropriate conflict management plan or will require that the SFI producing the COI be eliminated.

Conflict of Interest Disclosure Form    Conflict of Interest Policy