Policy Overview

Brandeis University is committed to overseeing the conduct of research in a manner that ensures the integrity of the research process and maintains the public trust and that of sponsors in the integrity and credibility of its faculty, its staff, and its research programs.

This commitment requires Brandeis University to ensure that research results are not biased by the external financial interests of persons who are responsible for the design, conduct, reporting, or direct administration of sponsored research. As a result, Brandeis University has instituted the Policy on Financial Conflicts of Interest in Research.

In accordance with this policy, all externally funded investigators, regardless of funding source, must report their external significant financial interests in a timely manner so that actual, potential, and apparent financial conflicts of interest can be identified and responsibly managed.

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SOME USEFUL DEFINITIONS

Conflict of Interest

A situation in which financial or other personal considerations may compromise, or have the appearance of compromising, an Investigator’s judgment in conducting or reporting Research.

Financial Conflict of Interest

A Significant Financial Interest (or, where the Institutional Official requires disclosure of other Financial Interests, a Financial Interest) that the Institution reasonably determines could directly and significantly affect the design, conduct, or reporting of Institutional research.

Financial Interest

Anything of monetary value received or held by an Investigator or an Investigator’s Family, whether or not the value is readily ascertainable, including, but not limited to: salary or other payments for services (e.g., consulting fees, honoraria, or paid authorships for other than scholarly works); any equity interests (e.g., stocks, stock options, or other ownership interests); and intellectual property rights and interests (e.g., patents, trademarks, service marks, and copyrights) upon receipt of royalties or other income related to such intellectual property rights and interests.

 Financial Interest does NOT include:

  • salary, royalties, or other remuneration from Brandeis University;
  • income from the authorship of academic or scholarly works;
  • income from seminars, lectures, or teaching engagements sponsored by or from advisory committees or review panels for U.S. federal, state or local governmental agencies; U.S. institutions of higher education; U.S. research institutes affiliated with institutions of higher education, academic teaching hospitals, and medical centers; or
  • equity interests or income from investment vehicles, such as mutual funds and retirement accounts, so long as the Investigator does not directly control the investment decisions made in these vehicles.

For PHS funded Investigators only, Financial Interest also includes any reimbursed or sponsored travel undertaken by the Investigator and related to his/her Institutional Responsibilities. This includes travel that is paid on behalf of the Investigator rather than reimbursed, even if the exact monetary value is not readily available. It excludes travel reimbursed or sponsored by U.S. federal, state, or local governmental agencies; U.S. institutions of higher education; U.S. research institutes affiliated with institutions of higher education, academic teaching hospitals, and medical centers.

Investigator

Any individual who is independently responsible for the design, conduct, or reporting of Sponsored Research, or proposals for such funding. This definition is not limited to those titled or budgeted as Principal Director/Investigator, co-Principal Director/Investigator, or co-Investigator on a particular proposal, and may include postdoctoral associates, senior scientists, or graduate students, as well as any other equivalent personnel as designated by the Principal Investigator or Institutional Official. The definition may also include collaborators or consultants as appropriate.

Research

A systematic investigation, study, or experiment designed to contribute to generalizable knowledge, including behavioral and social-sciences Research. The term encompasses basic and applied Research.

Significant Financial Interest

A Financial Interest that reasonably appears to be related to the Investigator’s Institutional Responsibilities, and:

  • if with a publicly traded entity, the aggregate value of any salary or other payments for services received during the 12 month period preceding the disclosure, and the value of any equity interest during the 12 month period preceding or as of the date of disclosure, exceeding $5,000; or
  • if with a non-publicly traded entity, the aggregate value of any salary or other payments for services received during the 12 month period preceding the disclosure exceeding $5,000; or
  • if with a non-publicly-traded company, an equity interest of any value during the 12 month period preceding or as of the date of disclosure; or
  • any income related to intellectual property rights and interests not reimbursed through the Institution.
Sponsored Research

Research, training, and instructional projects involving funds, materials, or other consideration from external sources.


AGENCIES SUBJECT TO APPENDIX A

Current PHS Agencies
  1. Agency for Healthcare Research and Quality (AHRQ)
  2. Agency for Toxic Substances and Disease Registry (ATSDR)
  3. Centers for Disease Control and Prevention (CDC)
  4. Food and Drug Administration (FDA)
  5. Health Resources and Services Administration (HRSA)
  6. Indian Health Service (IHS)
  7. National Institutes of Health (NIH)
  8. Office of Global Affairs (OG)
  9. Office of the Assistant Secretary for Health (OASH)
  10. Office of the Assistant Secretary for Planning and Evaluation
  11. Office of the Assistant Secretary for Preparedness and Response (ASPR)
  12. Office of Public Health and Science
  13. Substance Abuse and Mental Health Services Administration (SAMHSA)
Non-PHS Agencies
Please consult directly with the private agency in question.