Compliance with the Investigator Conflict of Interest Policy (P209)

If the DIO finds that an Investigator has failed to comply with this Policy or the means determined to resolve a Financial Conflict of Interest (FCOI) and/or Conflict of Obligation (CO), the DIO shall report the findings promptly in writing, including mitigating reasons behind the non-compliance and the proposed corrective action plan moving forward, to the Assistant Vice President for Research Compliance.

Upon review of the report, Assistant Vice President for Research Compliance (AVPRC), with concurrence by the Vice President for Research, will determine if:

• The mitigating reasons adequately provide reasonable explanation that the noncompliance was committed unintentionally,

• The corrective action plan is adequate to prevent recurrence • affected journals and/or funding agencies require notification to protect the public record, and

• The noncompliance was isolated, i.e., not involving potential violations of other University policies and/or federal regulations, including but not limited to human research protections

Depending on outcome of review, appropriate action will be taken by AVPRC, as follows:

• If the noncompliance is deemed unintentional with acceptable corrective action plan, and no other policies or regulations are impacted, the AVPRC will direct the DIO to notify the investigator, with copy to chair and dean, that the noncompliance has been acknowledged and the corrective action plan is to be initiated. Correspondence will also indicate if journals and/or funding agencies must be notified regarding the non-compliance.

• If other University policies and/or federal regulations have been potentially violated, appropriate University offices will be notified, and applicable processes initiated. The investigator will be notified of such by AVPRC, with copy to chair and dean.

• If the noncompliance is deemed intentional, regardless of other determinations, the VPR may proceed with initiation of disciplinary sanctions, which may include termination or alteration of the employment or academic status of persons against whom charges have been substantiated (and must be consistent with established University and Board of Trustees policies and applicable collective bargaining agreements). Article 19 of the UUP Agreement will be the sole source of University discipline for members of the UUP-represented unit. Additional sanctions may be rendered in accordance with applicable University policies. Upon completion of all disciplinary proceedings, the DIO will report to the cognizant federal agencies when federal funds are involved and to all other parties as necessary. The VPR will report this matter to the President.

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