This policy applies to all personnel, including all Members and full-time, part-time, temporary, and contract employees, of Yaya Scientific, LLC (“Yaya”) who are planning to participate in, or are participating in, National Institute of Health (“NIH”) funded research by: means of a grant or cooperative agreement.
The primary goal of this policy is to promote objectivity in research by establishing standards that provide a reasonable expectation that the design, conduct, and reporting of research funded under NIH grants or cooperative agreements will be free from bias resulting from Investigator financial conflicts of interest and to prevent an employee’s activities from adversely influencing Yaya’s operations.
It is recognized that research related conflicts of interest can arise from legitimate and appropriate activities including economic development, public-private interactions, and employee’s and their family’s personal business relationships.
This policy is implemented in accordance with 42 CFR Part 50 Subpart F – “Responsibility of Applicants for Promoting Objectivity in Research for which Public Health Service Funding is Sought” and 45 CFR Part 94 “Responsible Prospective Contractors” as well as all other relevant policies of federal funding and oversight agencies.
The design, conduct, and reporting of Research funded under NIH grants or cooperative agreements should be free from bias resulting from Investigator financial conflicts of interest.
To provide a reasonable expectation of achieving the goal of this policy, Investigators shall complete appropriate training as required under this policy; Investigators shall disclose perceived and real financial conflicts of interest annually and provide new or updated disclosures in a timely manner; Yaya shall provide for the elimination or management of Financial Conflicts of Interest; and Yaya shall make disclosures to both the NIH and to the public as required under this policy.
Nothing in this policy shall be construed to permit, even with disclosure, any activity that is prohibited by law.
Nothing in this policy shall be construed to limit or abridge the authority of Yaya members to take such action as they deem appropriate regardless of any action or inaction by an Officer of Yaya.
Company, through its President or Designated Appointee, shall require sub-recipient compliance with pertinent FCOI requirements as mandated by PHS regulation:
If applicable, obtain a certification from the subrecipient that its FCOI policy complies with the regulation.
If applicable, include in the written subrecipient agreement a requirement for the subrecipient to report identified FCOIs for its Investigators in a time frame that allows the Company to report identified FCOIs to NIH as required by the regulation.
Alternatively, if applicable, include in the written agreement a requirement to solicit and review subrecipient Investigator disclosures that enable the Company to identify, manage, and report identified FCOIs to NIH.
Company shall post this FCOI policy on the Company public website, as required by the regulation.
FCOI Informational requests by the public concerning identified FCOIs held by senior/key personnel should be made to the President or Designated Appointee. The President or Designated Appointee shall respond to requests for FCOI information within five (5) business days with minimum reporting elements as provided for under applicable regulations.
© 2023 Yaya Scientific, LLC | FCOI Policy
