If you need help, you can:
- contact the Conflict of Interest Administrator at 604-822-8623 or firstname.lastname@example.org
- talk to your faculty’s Associate Dean of Research whose position includes reviewing Conflict of Interest/Commitment Declarations at the faculty level. For the Faculty of Medicine, contact Deborah Money, Executive Vice-Dean, at 604-827-0327 or email@example.com. If you are not sure who the Associate Dean of Research is in your faculty, ask the Conflict of Interest Administrator.
To log into the RISe Database – http://www.rise.ubc.ca/
Quick Reference for Reviewers
- Top 5 Issues
- What Choices Do I Have in RISe?
- What’s a Management Plan?
- Summary of Significant Changes to UBC’s Conflict of Interest and Conflict of Commitment Policy and resulting changes to the RISe database
- Appointing Designates to review conflict of interest declarations in the RISe database
- Faculty Members and Family – Conflict of Interest Guidelines
- Who Can Be Exempted from a Conflict of Interest Declaration?
- Assigning Your Own Textbook to Students
UBC’s Conflict of Interest/Commitment Declaration in RISe asks 10 questions. To see the declaration and its 10 questions, click here.
If the person says “no” to all 10 questions, they get an automatic approval.
If they say “yes” to a question, they are asked for details. Links are provided suggesting what details to include. It is these declarations that come to you for review.
What to look for:
Conflicts of Interest are of three types:
- Conflicts of interest that are approved without a management plan because they are insignificant. For example, a gift worth $10 as the university policy says a gift must be declared if worth $500 or more.
- Conflicts of interest that are approved subject to a management plan which is a list of actions, limits and timelines to reduce or get rid of any negative impact of a conflict. For example, a professor’s niece must take a course with her next term as no other option exists.
- Conflicts of interest that are prohibited because they are significant and there is no way to reduce their negative impact.
Conflicts of Commitment are about time. If someone working for UBC has outside interests that are so substantial that they affect the ability of the person to do their UBC work that is a conflict of commitment. You can approve these conflicts if: 1) they have offsetting benefits to UBC or 2) they are not significant. An example of 1) is a professor’s book is being made into a documentary taking her away from the university for more than 52 days in one year. The benefits of the documentary to UBC might be significant enough to agree to the paid time away.
If you know of a conflict and the person who completed the Conflict of Interest/Commitment Declaration did not include it, you must tell them to include it and not approve the declaration until they have.
Ask yourself what a reasonable, skeptical but not fully informed observer would need to understand the situation.
Ask yourself “how would this look on the 6 o’clock news?” We call that the “smell test.” Consider three possibilities: actual conflict, future conflict, perceived conflict. The “future” includes at least the next 12 months. “Perceived” conflict is difficult as perception of bias or perception that harm might come to a human subject of research can be as damaging as actual bias or harm.
Review sensitive areas:
- Students including graduate students are not exploited (or perceived as such) for the private gain of their mentors
- Students including graduate students are free to choose and pursue research
- There are no restrictions on publications or dissemination of research results
- An open academic environment is maintained
- Use of UBC resources and facilities is appropriate to the issue
- Are there human subjects involved? Could they be harmed?
- Could personal financial interest have a significant effect on research? Or be seen to do so?
- Is it clear who will have rights to any intellectual property? Is UBC’s right to intellectual property clear and protected?
- If this conflict was disclosed in all publications and public discussions, how would it be received? Would UBC and all involved be seen as ethical and open or not?
- Is a human resources or admissions decision involved?
Has the faculty member whose Conflict of Interest/Commitment Declaration you are reviewing been complete in addressing all the areas you would want addressed? Has he/she included actions, limits, etc to offset any problems – real or perceived?
[With permission of and our thanks to Stanford University]
What is a Management Plan?
“Managed” means agreeing to a list of actions, limits and timelines to reduce or get rid of any negative impact of a conflict. These actions, limits and timelines are called a management plan and all the agreed actions, limits and timelines go into the person’s Conflict of Interest /Commitment Declaration.
Creative yet ethical ways to reduce or get rid of any negative impacts are welcome. If a niece or nephew must take a course with a professor, could the professor take a required-but-delayed leave for that term? Could a niece or nephew take the course through distance education elsewhere and the professor be their mentor?
Who drafts the management plan?
It is the job of the person completing their Conflict of Interest /Commitment Declaration to draft a management plan and sometimes they do not know what to do or how to do it. As a reviewer, you should offer to help.
If you and the person you are reviewing are not able to agree on a management plan, either of you can: 1) ask the next level up, usually an Associate Dean, to help 2) ask UBC’s Conflict of Interest Administrator for advice. You can reach the Conflict of Interest Administrator at firstname.lastname@example.org or 604-822-8623.
Suggestion: as RISE can be cumbersome to work in, you are welcome to discuss any changes needed by email, phone or in-person and then, when everyone is agreed, use RISe for the last step.
Some management plan examples: here
Reviewer – your options when reviewing in RISe
When reviewing a Conflict of Interest/Commitment Declaration in the RISE database, these are the options you have:
- Approve the Conflict of Interest/Commitment Declaration as is.
- Approve the Conflict of Interest/Commitment Declaration with a comment or restriction. When you choose the “Approve” option, a comment box will open and you can enter any restrictions there.
- Ask for changes to the Conflict of Interest/Commitment Declaration by choosing the “Changes required by…” option. Suggestion: as RISE can be cumbersome to work in, you are welcome to discuss any changes needed by email, phone or in-person and then, when everyone is agreed, use RISe for the last step.
- Send the Conflict of Interest/Commitment Declaration to the next level for review by choosing “Refer to Faculty Reviewer.” The Faculty Reviewer will be the Associate Dean of Research in larger faculties and the Dean in smaller faculties. You might choose this option if you are part of the same conflict or if the conflict is too complex for you to fully understand given your experience.
- Prohibit all activities in the Conflict of Interest/Commitment Declaration by choosing “Prohibited by…”
- If the Conflict of Interest/Commitment Declaration has been sent to your department/faculty in error, send it back to the person by choosing “Re-submit.” When the comment box opens, please add an explanation, if possible.
Note: as soon as you choose any of these options, an automated email is sent to that person telling them.
UBC’s Conflict of Interest committee – a Conflict of Interest/Commitment Declaration can also be sent to the committee for review and a decision if the first two review levels (Initial and Faculty) are not enough. To find out more, contact the Conflict of Interest Administrator at 604-822-8623 or email@example.com
Who must have an up to date Conflict of Interest/Commitment Declaration in RISe?
- All faculty members – for a complete list, see here
- Anyone with active research at UBC who is a principal investigator or co-investigator. In June 2010, we tied together the release of funding to an up to date Conflict of Interest/Commitment Declaration in RISe for anyone who is a principal investigator.
Exemptions in the Faculties of Medicine, Pharmaceutical Sciences, and Land & Food Systems: Clinicals in these three Faculties can be exempted from a Conflict of Interest/Commitment Declaration if 1) they have no research and no plans for research and 2) their division or department head okays the exemption in an email to the Conflict of Interest Administrator at firstname.lastname@example.org.