Announcement: The USC Office of Ethics Culture and Compliance (OCEC) has issued a revised COI in Research policy and supplemented procedures that are now effective. While the key principles to disclose, review and manage financial conflicts of interest in research remain unchanged, there are a few changes and additions.
A summary of these changes and additions is below:
- Malign Foreign Talent Recruitment Program (MFTR) Participation – Participating in a Malign Foreign Talent Program when prohibited by a federal research sponsor is a prohibited conflict under the new policy. Malign Foreign Talent Programs are defined as talent programs sponsored by a foreign country of concern as defined by the United States Government or an entity in a foreign country of concern. These programs are of special concern as they can also require activities such as the recruitment of additional researchers or unauthorized transfer of intellectual property, materials, data, or other nonpublic information developed with federal research funding. For more details on this please see the prior DCG Newsflash.
- Sponsor Required Training –The updated policy explicitly addresses PHS’ long-standing requirement that PHS-supported investigators must complete required training at least every four years, and immediately when any of the following circumstances apply:
- USC revises its financial conflict of interest policies or procedures in any manner that affects the requirements of Investigators;
- An Investigator is new to USC; or
- USC finds that an Investigator is not in compliance with this policy or any management plan imposed to mitigate the appearance of a conflict.
- Sponsor Required Reporting- As required by sponsors, OCEC will continue to provide initial and ongoing reporting to sponsors (e.g. PHS) as required under federal regulations. This includes reporting conflicts of interests prior to the expenditure of sponsor funds, as required.
- Addition of PHS-specific Procedures – The associated procedures have been enhanced to include a PHS specific section covering review requirements, record retention, reporting requirements, retrospective reviews and requirements for subrecipients.
Additional Training Required for Investigators:
Please note that Public Health Service (PHS) regulations require that any PHS researchers must complete training whenever the financial conflict of interest policy is revised. OCEC will be reaching out to PHS investigators over e-mail to complete this quick (5 minute) training on the policy and procedure revisions. Completion of this training will not be recorded by OCEC and will not appear in the Cayuse Admin tab. Completion of this training is not required prior to proposal submission and/or award set-up but should be completed promptly in compliance with COI Policy and Federal Sponsor Policy guidance.
Questions? If you have any questions, please feel free to reach out to Ben Bell in the Office of Culture, Ethics, and Compliance.