Accuhealth Technologies Inc. / Health 360x COI Management Principle:
While the federal rules for COI regarding Phase I SBIR projects are exempt from some COI requirements, the principles that govern Accuhealth Technologies require the disclosure of commercial relationships and implementation of a conflict management plan (CMP). This is especially important when working with investigators at universities and government entities.
The Accuhealth Technologies Inc./Health 360x Pl is responsible for ensuring that the following requirements are met:
1. The Accuhealth Technologies's proposal to the sponsor must clearly describe the relationship between the university researcher and Accuhealth Technologies Inc., so that the sponsor can make the funding decision with full knowledge of the potential conflict.
2. When ACCUHEALTH TECHNOLOGIES is applying for and/or awards a contract to an equity holder in Accuhealth Technologies, the awardee must disclose to their university OSP (1) a copy of the solicitation and the complete proposal and budget for the sub-contract and (2); the complete proposal submitted by ACCUHEALTH TECHNOLOGIES (if not available at the time of submission, the documents should be provided immediately post- submission); and
(3) indicate:
I. the labs and other locations where work will be conducted
II. the role of any university students and staff in the research;
III. whether any ACCUHEALTH TECHNOLOGIES employees or representatives will be involved in the university portion of the work and if so, a description of their involvement.
IV. documentation from ACCUHEALTH TECHNOLOGIES that it has a primary operating space outside of the University.
The Company's Mission:
Such company research is facilitated and/or made possible through external funding from private as well as public sources. It is the Company's responsibility to assure the integrity of all aspects of such sponsored research while, simultaneously, taking care not to discourage the development of external funding opportunities. The purpose of this document is to identify situations where potential conflicts of significant financial interest are likely to arise and to establish a process whereby such conflicts are either avoided or at least managed equitably to the satisfaction of all concerned parties.
a) Managing Conflicts of Significant Financial Interest
This document articulates Company policy on the management or elimination of conflicts of significant financial interest between outside constituencies and the associated funded activities carried out by Company . While this policy focuses upon avoiding, or at least managing, conflicts of significant financial interest, its primary purpose is to promote compliance with the standards of Objectivity in Research.
DEFINITIONS
a) Conflict of Significant Financial Interest is considered to occur whenever a Company employee, or a family member of the Company employee, has an existing or potential financial or other material interest that impairs, or appears to impair, the Company employee 's independence and objectivity in the discharge of his/her responsibilities to and/or for the Company; or, alternatively, conflict of significant financial interest is considered to occur whenever a Company employee receives financial or other material benefit through inappropriate use of knowledge or information confidential to the Company.
b) Company Employee is any individual employed on a full- or part-time basis by and is receiving, or will receive, compensation for such employment . {Includes Consultants, Agents and Research Collaborators of Company) .
c) Investigator is the principal investigator, co-principal investigators, or any other Company employee responsible for the design, conduct, or reporting of externally funded scientific research activities.
d) Family member includes the Company employee's spouse and children or other adults who qualify as dependents under the Internal Revenue Code definitions.
e) Project implies any externally funded activity such as basic, applied, or developmental research, or other activity conducted by Company employees on behalf of the Company.
f) Significant Financial Interest is any item of monetary value including, but not limited to:
i) salary or other payments for services rendered such as consulting fees;
ii) equity interests such as stocks, stock options, or other ownership interest; and
iii) intellectual property rights such as patents, copyrights, and royalties from such intellectual property rights.
Significant Financial Interest does not include: