111.11 Organization Policy on Financial and Personal Conflict of Interest Policy for IRB Members

Summer 2020

It is the policy of the Organization that JHM IRB members, including OHSR staff members who have been designated as alternate IRB members, will not review, participate in the discussion of, or vote upon any research protocol for which they serve as principal investigator or co-investigator, or which is sponsored by a company in which the committee member holds a financial interest, meaning anything of monetary value, including, but not limited to, salary or other payments for services (e.g., consulting fees or honoraria); equity interests (e.g., stocks, stock options, or other ownership interests); and intellectual property rights (e.g., patents, copyrights, and royalties from such rights). Uncompensated relationships giving rise to a conflict of interest, such as board of directors or other executive service, would similarly disqualify a member. Additional conflicts may include:

  • Involvement in the design, conduct, or reporting of the research
  • Involvement of immediate family members in the design, conduct, or reporting of the research

IRB members with these types of conflicts of interest may provide information about the protocol as requested by the IRB, then shall recuse themselves from the meeting during the discussion and vote on all such studies. In addition, IRB members with conflicts of interest may not act as the primary reviewer for exempt or expedited applications or expedited changes in research.

IRB members with a conflict of interest cannot participate in:

  • Review of unanticipated problems involving risk to participants or others.
  • Review of non-compliance with regulations or laws or the requirements of the IRB.