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UTMB Shares Strategies to Reduce Noncompliance with COI Policies

When confronted with an allegation of violating a conflict of interest (COI) policy, faculty and employees will commonly claim they just didn’t know they had done anything wrong. “So, it’s vitally important that employees have an awareness or an understanding of the relevant regulations and institutional policy,” said Craig Conway, associate vice president of institutional compliance at the University of Texas Medical Branch (UTMB) in Galveston.

An employee who is noncompliant due to ignorance is likely to face a different institutional response than a “person who knew the requirements and then willfully chose to ignore them,” he added. Conway recently discussed different types of COI policies during a session at the HCCA Research Compliance Conference.[1]

In terms of how institutions should respond, knowing the reason will help officials select the appropriate sanction.

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