As an academic institution, The Mount Sinai Health System must avoid all appearances of improper professional behavior by the Institution, its faculty, employees and trustees. A conflict of interest in research may arise when an Investigator/Covered Person and/or the Institution (as defined below) has a financial interest which could directly and significantly affect the approval, design, conduct, monitoring or reporting of a research study. Situations can occur in which an independent observer might reasonably conclude that the potential for private gain could be influencing the outcome of a research study. Even in the absence of an actual conflict of interest, such situations may require actions to minimize the appearance of a conflict.
This Policy seeks to safeguard the reputation for academic integrity of both Mount Sinai and its investigators’ by setting out requirements for disclosing potential conflicts of interest in research and the procedures for reviewing such disclosures and determining what corrective measures, if any, should be instituted. This Policy is based on the standards set forth in the federal regulations governing research funded by the Public Health Service (PHS) or the National Science Foundation (NSF) and the recommendations promulgated by the Association of Academic Medical Centers. The policy is predicated on full disclosure of all potential conflicts. The Financial Conflicts of Interest in Research Committee reviews the information to assess whether a potential conflict exists, and, if so, whether any additional steps are necessary to protect the integrity of the research and the investigators. Furthermore, clinical trials to evaluate the safety and efficacy of a drug, medical device or treatment, and research on technology in which the Investigator/Covered Person and/or the Institution has an ongoing financial interest, are subject to the most rigorous review and stringent conditions.