Subject: Comments on COI lite, for the record
To: Peter B Gilkey <gilkey@uoregon.edu>
Cc: grierm@uoregon.edu Add to address book...
From: Brad Shelton <shelton@uoregon.edu> 
Date: Tue, 27 Jan 2009 22:15:37 -0800


Dear Professor GIlkey,

We have a long-running gag in my family. Every year my children ask
me, "Daddy, what do you want for Christmas."
I always answer the same - "Time and Patience." It's not a very
funny gag. But my children, perhaps unlike some members of my
University's administration, understand the moral.

I appreciate your efforts to craft documentation and processes
relating to the issues surrounding institutional
Conflict of Interest. The document "COI lite" represents a
substantial improvement over earlier drafts of similar documents.

I would like to make several suggestions.

1. The reporting document needs a short preamble stating something
similar to:

"If this is the first time you have used this form, or if you have
not filed this form in the past thirteen months, then please proceed
forthwith. If you have filed this form in the past thirteen months
and furthermore there are NO SUBSTANTIVE CHANGES to your answers to
any of the questions (including any accompanying explanations), then
attest to that fact here - you need proceed no further. Otherwise,
please continue to complete the entire form."

While I'm sure that you can craft much better language for this
preamble, you will no doubt observe that including such a preamble
will greatly reduce duplication of effort on the part of both our
faculty and the central administration's staff.

2. Would it be possible to tighten the language in questions 1 and
2 in such a way that it would be practically impossible for a
respondent to think that he or she should answer YES to both
questions FOR THE SAME REASON? This is a minor point and I am not
sure how to achieve it.

3. There are seven footnotes in the reporting portion of the
document. Six of the seven serve as definitions of words or phrases
and are appropriate. The seventh footnote, number 4, is instead an
example and is inappropriate to the document. I suggest removing
that footnote and rewording question 3 as follows (keeping footnotes
3 and 5):

Question 3: If you are seeking or have been awarded funds from the
Federal Government, do you have a significant interest, financial or
other, in any business, entity or organization that could reasonably
be interpreted to cause impaired objectivity in regards to your
federally funded research?

It is conceivable that this version of the question does not have the
same meaning as intended by your original question. If so, a
substantive discussion is in order.


4. The placement of the word "other" in question number 4 is
problematic. The question itself is problematic, since it is far too
broad. Unless I misunderstand the question, you are asking something
logically equivalent to:

Question 4: Are you involved in any non-University professional
activities for which you receive substantive income, other than any
involvement covered by the previous questions.

Additionally, I would be interesting in knowing the exact definition,
for the purposes of the document, of the
phrase "substantive income," along the lines of footnote number 5.
Perhaps a careful definition at this point would reduce the scope of
the question appropriately.

5. In question 6, the phrase "potential of interest" should,
presumably, be replaced by the phrase "potential for conflict of
interest."

6. Question 7 should proceed question 4 (assuming my interpretation
of question 4 is correct).

7. Anyone with a Federal research grant will need to answer YES to
question number 1. Unless I am mistaken, we are already producing
conflict of interest documentation to accompany those grants. There
should be no reason to recreate or paraphrase that documentation on
the University's COI reporting form. It is not clear to me how to
rephrase the final page of the reporting document to take this into
account, but it should be thought through. If the new reporting
document is meant to supplant the other documentation efforts, then I
retract the suggestion.

Thank you again for your efforts on behalf of the University. I hope
that my suggestions are helpful and have not deprived you of any
quantity of those two precious commodities I eluded to earlier.

Respectfully,
Brad Shelton
Professor of Mathematics