Disclosure process
The Intellectual Property and Institutional Review Committee (IPIRC) may also assist in the evaluation and disposition of faculty financial conflicts of interest. The committee is made up of faculty and staff representing the diversity of academic and research disciplines of the university.
IPIRC meetings are currently held virtually typically every quarter, unless noted otherwise. Upcoming meetings are scheduled for:
| Meeting Dates - For FY2024 | |
|---|---|
| TBD | TBD |
| TBD | TBD |
| TBD | TBD |
| TBD | TBD |
If you are not involved in research, you may complete a conflict of interest disclosure through the Office of General Counsel.
For disclosure please use the Enterprise Research Administration System (ERA) MyDisclosures portal. See the following training video: Update Your Disclosure Profile - Changes for assistance.
Review Process
Once an investigator has made a disclosure, the MyDisclosures system will notify the supervisor that the investigator has submitted a financial disclosure for the supervisor to review and acknowledge.
ORIA reviews the financial interest disclosure and makes a recommendation regarding any potential financial conflicts of interest. If ORIA determines that no financial conflict exists or that disclosure only is required, ORIA will notify the individual who filed the disclosure.
If ORIA determines that the disclosure is a significant conflict of interest, the office will work with the investigator to set up a management plan to appropriately manage the conflict and identify a plan monitor to monitor compliance with the management plan. Once the investigator and ORIA reach a management plan agreement, the investigator, plan monitor, and the institutional official will sign the management plan to formalize the agreement.
The investigator may not initiate research until an agreement on a management plan is reached.
ORIA also reports significant financial interests that are disclosed to ASU Financial Services as part of ASU compliance with the State procurement laws. ORIA will work with the investigator to eliminate or appropriately manage the conflict if/when procurement activity with the conflicting entity arises.
Management Plans
To manage a significant financial conflict of interest, conditions or restrictions may be instituted which can include, but are not limited to:
- disclosing significant financial interests to all co‐investigators and trainers, and to journal editors
- disclosure in publications, presentations and, in the case of human research, the informed consent document
- monitoring the research by independent reviewers
- designating a substitute PI (peer or superior) who has no significant financial interest in the project
- modifying the research plan to manage, reduce or eliminate the conflict of interest
- disqualifying participation in all or a portion of the research
- divesting significant financial interests
- severing relationships that create actual or potential conflicts
Arizona state law may require the management of conflicting financial interests that arise if ASU enters into contracts for supplies, including subcontracts or with awards to third parties under sponsored projects.
Reporting
ASU will hold disclosures in confidence, except for business purposes or when required by law to disclose it. Where appropriate, ASU may share this information with supervisors and appropriate ASU, ABOR and Skysong Innovations, LLC administrative personnel in conducting the review under the applicable policies. ASU may also share information on conflicts of interest with sponsors when required by the sponsor.
For PHS and DOE-sponsored research, the regulations require public accessibility of disclosures when a request is made under a public records request or the Freedom of Information Act. When a public request is made, ASU will provide a written response within five (5) business days, as required, for financial interests that meet the following criteria:
- The significant financial interest was disclosed and is still held by key personnel
- The review determined that the significant financial interest is related to the PHS or DOE-funded research
- The review determined that the significant financial interest is a financial conflict of interest
For financial interests that meet the criteria, ASU will disclose the following information:
- the investigator’s name
- the investigator’s title and role with respect to the research project
- the name of the entity in which the significant financial interest is held
- the nature of the significant financial interest
- the approximate dollar value of the significant financial interest using the following ranges:
- $0–$4,999
- $5,000–$9,999
- $10,000–$19,999
- $20,000–$100,000 by increments of $20,000
- amounts above $100,000 by increments of $50,000; or
- a statement that the interest is one whose value cannot be readily determined through reference to public prices or other reasonable measures of fair market value.
Under DOE Interim COI policy, responses to written public requests will require confirmation that the information provided is current as of the date of the correspondence and is subject to updates, on at least an annual basis and within sixty days of identification of a new financial interest, which should be requested subsequently by the requestor.
Information concerning the significant financial interests must remain available for at least three (3) years from the date that the information was most recently updated.