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    California Pacific Medical Center
    Conflict of Interest

    For questions and help, please call:
    CPMC Research Institute
    (415) 600-1600


    Introduction  |  Definitions  |  What is exempt from being disclosed?

    Introduction

    The Research Institute Conflict of Interest policies regarding disclosures have not changed, so you are being asked to reveal any "financial interests which may compromise or have the appearance of compromising an investigator's professional judgment in conducting or reporting research". You must disclose your relevant financial interests as well as those of your spouse, your domestic partner or your dependent children.

    Our policy does not provide for a threshold below which you are not required to disclose financial interests. Instead, we ask that all financial interests that could be related to your research at CPMC/CPMCRI be disclosed; our experience has been that most disclosed financial interests are not an issue. Please know that the potentially sensitive information you give us will remain as confidential as regulations allow, COI committee members and staff sign a confidentiality agreements to further protect disclosure. We will discuss any disclosures with you before they can be released beyond the COI Committee, the IRB or research participants. The COI Committee includes both laboratory and clinical researchers.

    Understanding and dealing with financial conflicts of interest is an important part of research compliance, so it is essential that you return the COI disclosure to us.


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    Definitions

    • Financial Conflict of Interest is a significant financial interest that could directly and significantly affect the design, conduct or reporting of research.

    • Financial Interest is anything of monetary value, whether or not the value is readily ascertainable.

    • Institutional Responsibilities: means an investigator’s/individual’s professional responsibilities on behalf of CPMC/Sutter, including activities such as research, research consultation, teaching, professional practice, medical directorship, clinical practice, institutional committee memberships, and service on panels such as Institutional Review Boards or Data and Safety Monitoring Boards.

    • Significant Financial Interest (SFI) means: A financial interest consisting of one or more of the following interests of the Investigator (and those of the Investigator’s spouse, domestic partners and dependent children) that reasonably appears to be related to the Investigator’s institutional responsibilities:
      1. SFI exists if the value of any equity interest or any remuneration received from a publicly traded entity exceeds $5,000. Remuneration includes salary and payment for services (such as consulting fees, honoraria, paid authorship); equity interest includes any stock, stock option, or other ownership interest, as determined through reference to public prices or other reasonable measures of fair market value;

      2. SFI exists if the value of any remuneration received from a non-publicly traded entity exceeds $5,000, or holding any equity interest (e.g., stock, stock option, or other ownership interest)

      3. SFI exists if income is received from intellectual property rights and interests but those not owned by the Institution.



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    What is exempt from being disclosed?

    • salary, royalties or other remuneration paid by the Institution to the Investigator/individual if the Investigator/individual is currently employed or otherwise appointed by the Institution including intellectual property rights assigned to the Institution and royalty sharing agreements related to such intellectual property rights;

    • income from investment vehicles (e.g. mutual funds, retirement accounts, etc.) in which the Investigator/Individual does not directly control the investment decisions of these vehicles;

    • income from seminars, lectures or teaching engagements sponsored by a federal, state or local government agency, an institution of higher learning, an academic teaching hospital, a medical center or a research institute that is affiliated with an institution of higher education;

    • income from service on advisory committees or review panels for a federal, state, or local government agency, an institution of higher education, an academic teaching hospital, a medical center, or a research institute that is affiliated with an institution of higher education;

    • travel that is reimbursed or sponsored by a federal, state, or local government agency, an institution of higher education, an academic teaching hospital, a medical center, or a research institute that is affiliated with an institution of higher education; or

    • Small Business Innovation Research (SBIR) Phase I applications.


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