COI Training and Other Information

Required COI Training

Faculty who receive PHS funded grants and contracts MUST complete on-line training about Conflicts of Interest before any funds for new grants or competing/non-competing renewals that are received by Stanford.

In addition, Stanford requires all newly-hired faculty to complete training on identifying and reporting conflicts of interest. 

COI training provides an overview of high-risk situations which can lead to conflicts of interest for faculty.

Launch Course Here

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Best Practices for Faculty Start-Ups

Stanford is committed to avoiding either perceived or actual conflict of interest issues with respect to faculty start-ups. Both Stanford and faculty have responsibilities to optimize technology transfer and mitigate COI whenever licensing Stanford intellectual property to a faculty start-up is considered.

University/Office of Technology Licensing (OTL) Responsibilities

Make licensing decisions based on OTL’s professional judgment about technology transfer to achieve the best possible benefit to the public, without undue influence from internal or external parties. View the OTL Inventors Guide. .

To determine the most effective way to transfer the technology:

  • OTL “markets” all Stanford technology to ensure fair and open access to potential licensees:

    • Faculty start-ups should not receive or be perceived as receiving preferential treatment.

  • Stanford faculty/employees are not allowed to represent the potential licensee and must not negotiate directly with OTL.

  • The faculty’s School Dean and the Dean of Research must review any actions that present a potential conflict of interest:

    • If OTL, after thorough marketing, determines that a faculty-affiliated company is the appropriate licensee, OTL documents its marketing and rationale for its licensing decision.

    • The faculty must disclose to the Deans any interest (consulting fees and/or options) in the start-up.

    • The faculty must agree to separate University responsibilities from company responsibilities according to the criteria listed under Faculty Responsibilities, below.

    • If the conflict is deemed manageable by the Deans based on this agreement with the involved faculty, OTL may proceed with the licensing.

  • OTL licensing agreements may be exclusive or non-exclusive depending on what is most suitable for achieving technology transfer.

Faculty Responsibilities

Separate University duties for research and education from personal financial interests in the company.

Faculty must:

  • Separate and clearly distinguish on-going University research from work being conducted at the company.

  • Limit consulting for the company to a maximum of 13 days a quarter, per University policy.

  • Serve only in advisory or consultative roles at the company:

    • Do not take managerial roles or titles (i.e CTO) suggesting management responsibility.

    • Take a leave of absence from Stanford if engaging in a management role.

Faculty must not:

  • Negotiate with the University on behalf of the company.

  • Receive gifts or sponsored research from the company.

  • Involve research staff or other University staff in activities at the company;

    • Company personnel cannot be affiliated with the University.

  • Involve company personnel in Stanford research.

  • Involve current students in company activities:

    • If a student asks to take a leave of absence to participate in the company, refer the student to the School Dean for review of the request and independent advice.

  • Involve junior faculty in company activities for whom you have supervisory responsibility:

    • Even if no supervisory role, avoid situations in which junior faculty might feel expected to be involved.

  • Use University facilities for company purposes.

  • Undertake human subjects research at the University as PI/protocol director.

  • Supervise faculty who are PI/protocol directors for human subjects research related to the company.

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Request for Information on Identified Financial Conflicts of Interest (FCOIs) in PHS-funded Research

In order to request information on a Financial Conflict of Interest (FCOI) identified on or after 8/24/12 related to Public Health Service (PHS) sponsored research, please click this link to make such a request. This form must be completed and returned via email to facilitate a timely response.

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Responsible Conduct of Research Casebook

The HHS Office of Research Integrity has posted a new responsible conduct of research casebook. The teaching resource features cases organized on the following topics: authorship and publication, research misconduct, collaboration, data acquisition and management,conflicts of interest, peer review, mentor and trainee relationships, and social responsibility.

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CMS's Open Payments Physician's Database (Sunshine Act)

Physicians who received payments or gifts from pharmaceutical or medical-device companies in the previous fiscal year should allocate several days before the May 15th deadline to register, affirm or dispute any errors in reporting on the government’s Open Payments database. This data will be made public in an online database on June 30th of each year. 

Please print out the Tips to use when registering at http://portal.cms.gov

Frequently asked questions by Stanford Faculty:  FAQs

 (If a Physician disputes data reported by Industry in the Open Payments database and it has not been resolved by the deadline, the public database will still publish the amounts but with a “disputed” notation.)

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CMS's Open Payments Training Slides

Correspondence from Association of American Medical College (AAMC)

Dear Colleagues,

We are pleased to share that the CMS Open Payments team, in consultation with the AAMC’s FOCI Steering Committee and AAMC Staff, have developed two educational resources for your use: one contains information to educate physicians about the Open Payments program and another for authorized representatives of teaching hospitals.

The Open Payments review and dispute period for physicians and teaching hospitals begins on April 1 and ends May 15 each year.

The resources are available in PowerPoint format on the AAMC’s Open Payments website and are specifically designed to be distributed as a complete slide deck. Please click here to access the Open Payments resources or use the links below.

If you have any questions or need assistance with the Open Payments program, please contact the CMS Open Payments Help Desk at openpayments@cms.hhs.gov or by calling 855-326-8366.

Links:

https://www.aamc.org/openpayments

https://www.cms.gov/openpayments/

Sincerely, Association of American Medical College  

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