The Senate Ad-Hoc COI/C Committee

Membership:

• John Bonine , Law email: jbonine@uoregon.edu (541) 346-3827
• Jim Brau, Physics email: jimbrau@uoregon.edu (541) 346-4766
• Rob Horner, Education email: robh@uoregon.edu (541) 346-2462.
• Richard W Linton, VP for Rsch & Graduate Studies (Chemistry Dept), rlinton@uoregon.edu, (541) 346-2090
• Russ Tomlin, Snr Vice Prov for Acad Affrs (Linguistics Dept), tomlin@uoregon.edu. (541) 346-3029.
• Kyu Ho Youm, Journalism email: youm@uoregon.edu (541) 346-2178
• Lynette Schenkel (Assistant Vice President for Research) [non-voting] schenkel@uoregon.edu (541) 346-3472.
• Meg Rowles (Interim Assistant Director of ORCR -- Committee Staff) mrowles@uoregon.edu (541) 346-3863.

Date: Fri, 12 Dec 2008 11:07:43 -0800

MEMORANDUM

December 12, 2008

To: All Officers of Instruction, Officers of Research, and Officers of Administration

From: R. Linton, Vice President for Research and Graduate Studies
R. Tomlin, Senior Vice Provost for Academic Affairs
Paul van Donkelaar, President of the UO Senate

Subject: Continued COI-C Policy Review

There have been a considerable number of thoughtful and substantive comments conveyed by faculty colleagues on the draft policy on Conflict of Interest and Commitment (COI-C). In response, the planned January 2009 roll out of the new disclosure process for COI-C will be suspended for an appropriate period of time to review and address the concerns expressed on the 'blog' or that have been communicated directly to Academic Affairs or the Office of the Vice President for Research and Graduate Studies. For the moment, then, the proposed new process is paused and existing policy and procedures will remain in force. Faculty with funding from agencies such as NIH or NSF, or whose research involves human subjects, will need to continue current disclosure practice as required by federal regulations.

We recognize the need to further review the draft policy and to include faculty more extensively in that effort to bring forward an integrated COI-C policy and effective implementation process. We have appreciated the careful and collegial concerns expressed by colleagues such as John Bonine from Law or Alec Murphy from Geography, along with advice from the Faculty Advisory Council (FAC), that supported the need to incorporate additional ideas and insights rather than to press forward prematurely. To that end, we have agreed that Senate President Paul van Donkelaar will convene a small ad hoc committee charged with reviewing and, where needed, suggesting revisions to the draft COI-C policy to meet essential legal and policy requirements with a keen sensitivity to academic freedom and the culture of a public research university. The members of the ad hoc committee will be posted as soon as Paul has confirmed their participation.

To proceed in this manner, the University requested (and received Wednesday afternoon) an extension of the January 31, 2009 deadline previously set with the OUS Internal Audit Division to the start of our next fiscal year, July 1, 2009. This extension permits at least a two-month period (January and February 2009) for a focused effort by the committee to consider the policy and associated disclosure form. It is anticipated that the revised draft will be presented at the March 11, 2009 UO Senate meeting. This permits, as needed, an additional period of review and comment by the faculty between March and June 2009. The new deadline to implement the disclosure policy and process, July 1, 2009, should allow sufficient time for better assimilation of both COI and COC issues. We're grateful for your help in moving forward in this way.

1. Conflict of Interest and Committment home page.
2. Letter 1 December 2008 to OIs, ORs and OAs from James Bean, Richard Linton, and Russ Tomlin concerning COI.
3. Section 4 of the OUS-IMD relating to Staff and Faculty Personnel (as of 17 Dec 2008).
4. Oregon Revised Statues. Chapter 352 -State and Independent Institutions of Higher Education (as of 17 Dec 2008).
5. Oregon Revised Statues Chapter 244 -Government Ethics (as of 17 Dec 2008).
6. Email dated 17 Dec 2008 from Prof. Bonine.
7. Email dated 7 January 2009 from Prof. Bonine.
8. AAUP Policy statements on conflict of interest.
9. Draft UO Policy on COI-COCC.
10. Faculty Employment Outside of the University: Conflicts of Commitment (2004) AAUP.
11. Archival documents
12. Document dated 7 January 2009 from Prof. Horner "Considerations for COI/COC policy and process".
13. Information Email to C. Bybee concerning the town hall meeting.
14. Document from Prof. Bonine concerning "Preliminary criticisms of Proposal (page 1 only) 10 January 2009.
15. Document critique of page 2 of the UO's draft policy 12 January 2009.
16. Information on the town hall meeting 21 January 2009.
17. Preliminary Report to the UO Senate 13 January 2009.
18. COI-COC Briefing Book. This contains MANY materials:
    • Tab 2 - Conflict of interest and commitment policy development background as of January 2009
    • Tab 3
      • Tab 3.1 Policy Statement 3.095 Personnel Practices - Guidlines for overload compensation for faculty.
      • Tab 3.2 Policy Statement 3.000 Personnel Practices - potential conflicts of interest.
    • Tab 4
      • Tab 4.1 Draft document Disclosure and management of indifidual conflicts of interest and commitment.
      • Tab 4.2 Conflict of Interest and commitment disclosure form.
      • Tab 4.3 Draft - November 2008 - COI-C Disclosure review guidlines.
      • Tab 4.4 Draft Charter Conflict of Interest/Commitment Committee.
      • Tab 4.5 Draft COIC managment plan guidlines.
      • Tab 4.6 Draft COIC Managment form template.
      • Tab 4.7 COIC Glossary
    • Tab 5 OUS Internal Audit Division March 2006
    • Tab 6 Policy Statements
      • Tab 6.1 University of Illilinois at Urbana Champaign
      • Tab 6.2 University of North Carolina
      • Tab 6.3 University of California Santa Barbara
      • Tab 6.4 University of Iowa
      • Tab 6.5 Stanford (Part I) and Stanford (Part II).
      • Tab 6.6 Univrsity of Colorado.
      • Tab 6.7 Oregon State University.
      • Tab 6.8 University of Washington.
      • Tab 6.9 University of Michigan.
      • Tab 6.10 University of Virginia.
      • Tab 6.11 Sample COI.
      • Tab 6.12 U Indiana at Bloomington (added 25 January 2009). See also Tab 6.12 6.12-a, Tab 6.12 6.12-b, Tab 6.12 6.12-c.
    • Tab 7 State and Federal Policies and Regulations Draft summary of COI and COC regulations. See also Tab7.1.a.pdf
    • Tab 8 Regulatory Guidance Materials
      • Tab 8.1 Recognizing and managing personal financial conflicts of interest COGR
      • Tab 8.2 AAU Report
      • Tab 8.3 Department of Health and Human Services Final guidance document financial relationships and interests in research involving human subjects: guidance for human subject protection
      • Tab 8.4 NIH Objectivity in research and NIH Reminder of financial conflict of interest requirements.
    • Tab 9
      • Tab 9.1 Email from Randy Geller to Lyneette Schenkel 8 Par 2008
      • Tab 9.2 Feedback of COI-C web site as of 1-8/09.
      • Tab 9.3 Email From Don Gerhart to Meg Rowles dated 12 December 2008.
19. Announcement of town hall meeting.
20. Campus Email 14 Jan 2009.
21. Email from P. Gilkey to G. Bolt 15 Jan 2009.
22. Email 16 Jan 2009 from William T Harbaugh.
23. Agenda 16 Jan 2009 Committee meeting.
24. Email from J. Bonine 16 January 2009.
25. Email from A. Murphy 16 January 2009.
26. Nine points to consider in licensing University Technology a document produced by the Association of University Technology Managers
27. Document from Prof. Ian McNeely 16 January 2009.
28. Email correspondence 18 January 2009 between John Bonine and Rob Horner. See also Oregon State Short Form
29. Stanford COIC Form
30. COI policy without COC policy as of 20 January 2009. Also see Document indicating deleted material.
31. Remarks by COI/COC Chair Gilkey at the Town Hall Meeting 21 January 2009.
32. Email of 21 Jan 2009 from Professor R. Mann concerning COIC
33. Letter as of 21 Jan 2009 from Professors Paris and Moffitt.
34. Email as of 22 Jan 2009 from Professor Jaeger.
35. Blog posted on the COI-C web page 22 January 2009 concerning the town hall meeting.
36. Email from Prof. McNeeley 22 Jan 09
37. Email correspondence between Professors Tomlin and Lininger 23 January 2009.
38. Minutes of the COI-COC committee meeting 16 January 2009 (posted 24 January 2009).
39. Tab 6.12 U Indiana at Bloomington (added 25 January 2009). See also Tab 6.12 6.12-a, Tab 6.12 6.12-b, Tab 6.12 6.12-c.
40. Email of 27 Jan 2009 transmitting a "lite" COI disclosure form to the committee for consideration.
41. Email as of 27 January 2009 from C. Phillips concerning the "lite" COI disclosure form.
42. Email as of 27 January 2009 from D. Koch concerning the "lite" COI disclosure form.
43. Town Hall Feedback
44. Email as of 27 January 2009 from S. Clark concerning the "lite" COI disclosure form.
45. Email as of 27 January 2009 from R. Horner concerning the "lite" COI disclosure form.
46. Email as of 27 January 2009 from H. Sadofsky concerning the "lite" COI disclosure form.
47. Email as of 27 January 2009 from I. McNeeley concerning the "lite" COI disclosure.
48. Email as of 27 January 2009 from R. Melnick concerning the "lite" COI disclosure.
49. Email as of 27 January 2009 from D. Hulse concerning the "lite" COI disclosure.
50. Email as of 27 January 2009 from B. Shelton concerning the "lite" COI disclosure.
51. Email as of 27 January 2009 from Yuan Xu concerning the "lite" COI disclosure.
52. Email 29 January 2009 by P. Gilkey.
53. Email dated 29 January 2009 from M. Jaeger.
54. Email dated 29 January 2009 from H. Lin
55. Email dated 30 January 2009 from C. Jones.
56. List of "Big Issues" related to the COI-COC as of 1 February 2009.
57. Correspondence 4 Jan 2009 concerning Notice of Motion at the March Senate Meeting.
58. Minutes of the 23 January 2009 meeting.
59. Letter from Russ Tomlin 4 February 2009 concerning COC.
60. Minutes 4 February 2009. concerning COI.
61. Minutes12 February 2009 concerning COI.
62. Minutes19 February 2009 concerning COI.
63. Minutes26 February 2009 concerning COI.
64. Cover letter 9 March 2009 from COIC COmmittee chair John Bonine to the campus community enclosing Sample COI financial disclosure form and Sample disclosure form.
65. Minutes4 March 2009 concerning COI.