Conflict of Interest

What is the role of the CIRC Committee?

If the director of the Office for Sponsored Projects and Research Activities (OSPRA), or their designee, identifies a potential conflict of interest that is more than minimal, they will arrange a meeting of the Conflict of Interest Review Committee (CIRC) to evaluate the proposal and disclosures. The investigator will be notified about the CIRC review and invited to the meeting to present their position and answer any questions from the committee. The potential conflict of interest will not delay the proposal’s processing or submission to the sponsoring agency. The Significant Financial Interest Disclosure and supporting documents will remain within OSPRA.

In its review, the CIRC will reach one of two conclusions:

• • That the potential conflict of interest is not proximate or significant enough to cause a concern for objectivity or integrity; or
  • That the potential conflict of interest is such that a significant financial interest could directly and significantly affect the design, conduct or reporting of the proposed project. In reviewing these disclosures, the Conflict of Interest Review Committee will act in a timely manner so as not to delay unduly the conduct of the project.
    
    

1. If the CIRC reaches the first conclusion, it shall document its determination and no further action shall be required.
2. If the CIRC reaches the second conclusion, it shall discuss with the investigator possible ways of reducing, managing or eliminating the potential conflict of interest. The investigator shall be informed that a Management Plan will need to be developed and approved prior to the expenditure of any award funds.
3. OSPRA will work with the investigator to develop and present to the CIRC a Management Plan that details proposed steps that will be taken to reduce or eliminate the potential conflict of interest. Methods adopted in the plan may include one or more of the following:
   • Public disclosure of significant financial interests
   • Review of research protocol by independent reviewers
   • Monitoring of research by independent reviewers
   • Modification of the research plan
   • Disqualification from participation in all or a portion of the research funded
   • Divestiture of significant financial interests
   • Severance of relationships that create actual or potential conflicts of interest
4. The CIRC shall review the resolution plan. The CIRC may modify the plan, including adding conditions or restrictions, before it approves the plan.
5. If the investigator is dissatisfied with the CIRC’S conclusion, the investigator may appeal to the provost and vice president for Academic Affairs who will consult with the Investigator and CIRC as the provost and vice president for Academic Affairs deems necessary and appropriate to the particular circumstance. The decision of the provost and vice president for Academic Affairs shall be final.
6. Violations of this policy or the terms of the Management Plan, such as willful concealment of financial interests, may result in sanctions being imposed upon the violating individual. If the violation results in a collateral proceeding under the institution’s policies regarding misconduct in science, then the CIRC shall defer a decision on sanctions until the misconduct in science process is completed. The CIRC will review allegations of violations and will make recommendations regarding the imposition of sanctions to the provost and vice president for Academic Affairs. The decision of the provost and vice president for Academic Affairs with regard to the imposition of sanctions shall be final subject to any rights the investigator may have under the grievance procedure contained in the Detroit Mercy-UDMPU Collective Bargaining Agreement. Retrospective reviews will be completed and documented within 120 days.