Policy

Financial Conflict of Interest Policy

Applicable to Public Health Service (PHS)-funded research, including NIH SBIR/STTR awards
Effective date: [EFFECTIVE DATE] · Last reviewed: [REVIEW DATE] · Version [1.0]
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1. Purpose and Scope

Litmus Analytical Inc. ("Litmus") is committed to conducting research with objectivity and integrity. This policy implements the PHS regulation at 42 CFR Part 50, Subpart F, "Promoting Objectivity in Research," and applies to every Investigator who is planning to participate in, or is participating in, research funded or proposed for funding by PHS, including NIH, and by any other agency that adopts these requirements.

2. Definitions

3. Training

Each Investigator must complete FCOI training before engaging in PHS-funded research, at least every four years thereafter, and promptly when this policy changes materially, when the Investigator is new to Litmus, or when the Investigator is found to be out of compliance.

4. Disclosure Requirements

Investigators must disclose all SFIs to the Designated Official:

5. Review and Determination

The Designated Official reviews each disclosure, determines whether the SFI is related to PHS-funded research and, if so, whether it constitutes an FCOI. Determinations are made before the expenditure of any award funds and within 60 days of any new disclosure during an ongoing award.

6. Management of Financial Conflicts of Interest

When an FCOI exists, Litmus will develop and implement a written management plan, which may include:

Litmus will monitor Investigator compliance with each management plan until the completion of the research project.

7. Reporting to the Funding Agency

Litmus will report identified FCOIs to the PHS awarding component (for NIH, through the eRA Commons FCOI Module) before spending award funds, within 60 days of any subsequently identified FCOI, and annually for the duration of the award, in accordance with 42 CFR 50.605(b).

8. Public Accessibility

This policy is publicly available on this website. Before spending funds under a PHS-funded award, Litmus will ensure that information about any identified FCOI held by senior/key personnel is available within five business days of a written request, including the Investigator's name, title and role, the entity in which the SFI is held, the nature of the SFI, and its approximate dollar value range, as required by 42 CFR 50.605(a)(5).

9. Subrecipients

When PHS-funded research is carried out through a subrecipient, Litmus will establish in a written agreement whether the subrecipient's FCOI policy or this policy applies, and set timelines for subrecipient reporting to Litmus.

10. Noncompliance and Retrospective Review

If an FCOI was not identified or managed in a timely manner, Litmus will complete a retrospective review within 120 days, determine whether research was biased, update any reports to the funding agency, and implement a mitigation report where required. Failure to comply with this policy may result in disciplinary action, up to and including termination of employment or other relationships with Litmus.

11. Records

Litmus will retain all disclosures, reviews, determinations and management plans for at least three years from the date the final expenditure report is submitted, or longer where required by the awarding agency.

12. Contact

Questions about this policy, or requests for FCOI information, may be sent to the Designated Official at info@litmusanalytical.com, Litmus Analytical Inc., 825 North 300 West, Suite NE 300, Salt Lake City, UT 84103.

References