The phrase "conflicts of interest" refers to issues involving time and energy (conflicts of commitment) and issues involving financial considerations (conflicts of financial interest). The two often overlap.
A conflict of commitment occurs when outside activities interfere with an employee's primary Hospital responsibilities. Consulting and outside activities can create real benefits for the faculty member and for the institutions involved; however, they can also interfere with work obligations, and can precipitate conflicts of financial interest.
Biomedical research collaborations between academia and industry can provide benefits through the development of new knowledge and technologies. At the same time, there is the potential for conflicts of financial interest that may arise from these situations. Special attention is focused on the relationships between faculty and pharmaceutical companies in the conduct of clinical trials. Conflicts of financial interest can erode scientific objectivity.
In the modern research environment, it is often difficult to avoid conflicts of interest. The goal of the Hospital's policy in this regard is therefore not to eliminate all conflicts but rather to manage them. The critical initial step to Children's Hospital conflict of interest process is DISCLOSURE. Within Children's Hospital, disclosure occurs on two levels:
- All Children's Hospital faculty are required to submit an annual disclosure and certification of compliance with the General Counsel's Office. CHOP-based Penn faculty also submit annual statements to both Penn and Children's Hospital. This statement should be kept updated between annual disclosures.
- Investigators are asked to submit a specific conflict of interest statement for each human subject research protocol in which they participate.
In addition to the Children's Hospital and Penn requirements, two of the Hospital's largest sponsors - the National Science Foundation (NSF) and the National Institutes of Health (NIH) - have their own requirements for financial disclosures whenever a proposal is submitted to either agency. Investigators are encouraged to review the NIH tutorial on financial conflicts of interest located in the "more information" tab.
It may be difficult to identify potential conflicts of interest. One way to become familiar with possible issues is to review the policy in its entirety. In addition, you can analyze hypothetical circumstances in which potential conflicts may present themselves.
Any issues related to financial conflict of interest should be discussed with the director of the Office of Compliance and Regulatory Affairs at the Children's Hospital of Philadelphia Research Institute. The Hospital's Office of Compliance and Privacy is also available to provide advice. Issues related to conflict of commitment should be addressed by your department chair.
Ask the Experts
Research Compliance and Regulatory Affairs
Deputy Compliance Officer, Research
Office of Compliance and Privacy
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CHOP Research Resources
- Responsible Department: Office of Research Compliance and Regulatory Affairs
- CHOP Conflict of Interest Policy
- CHOP Office of Compliance and Privacy
- National Academy of Science Conflict of Interest Information
- FASEB Conflict of Interest Toolkit
- NIH Tutorial on Financial Conflicts of Interest