Management Procedures
The College's Conflict of Interest (COI) management procedure ensures a fair and equitable review process for all disclosures. Completed disclosures that do not list any outside interests or relationships are automatically approved and closed with a status of "No COI Determined." If an actual or potential conflict is disclosed, the following steps will be initiated.
Note: See the Roles and Responsibilities table to identify your role.
Review Process (if a conflict is disclosed):
- Submission & Initial Review: The disclosee submits a form, which is then routed to their Area Designee (Chair or Supervisor) for initial review.
- Compliance Review & Committee Meeting: If a conflict is identified, the COI is routed to the Compliance team and a COI Committee for review and discussion.
- Management Plan Draft: The COI Committee drafts a management plan for identified conflicts.
- Plan Review & Signature: The Compliance Officer reviews the plan, and it is then reviewed and signed by the Area Designee and Disclosee.
- Final Approval & Record: The signed plan is shared with the area Vice President for approval and then uploaded to the Cayuse COI record, indicating the conflict's management status.
Roles and Responsibilities
|
Role |
Responsibility |
|
Disclosee |
Each faculty and staff member is required to submit a disclosure and is responsible for disclosing all relevant outside interests and relationships as defined in Teachers College Conflict of Interest and Commitment Policy. |
|
Area Designee |
A COI reviewer who is a department chair, supervisor or other leadership-level position within a unit and is responsible for the initial review of any potential conflicts disclosed by faculty or staff in their reporting line. |
|
Compliance Officer |
The Compliance Officer oversees the COI disclosure process at Teachers College, convenes the COI committee to review disclosures and create management plan as necessary, and ensuresthat management plans are foll owed. |
|
Conflict of Interest Committee (COIC) |
The COI committee includes the Vice Dean for Research, Compliance Officer and representatives from Administration, General Counsel, Faculty Affairs and Ad Hoc reviewers for subject matter expertise. This group is responsible for drafting management plans when conflicts arise due to relationships disclosed by faculty or staff members. |
|
Reviewers |
Depending on the conflict identified, several layers of reviewers can exist including the Area Designee, Compliance Officer and COI Committee. All COIs will be reviewed by the Area Designee, unless no conflicts are listed in the disclosure, at which point the process will end and not be reviewed. |