Research and other sponsored programs are governed by strict rules and regulations from sponsors, federal or state government, and CNE policies. The Compliance Department is here to help navigate the complexities of FCOI, foreign influence, sanction screening, and much more. Below you’ll find information on a wide variety of compliance issues commonly encountered during the lifecycle of an award.
Financial conflict of interest (FCOI) may occur when outside financial factors compromise or appear to compromise a researcher’s judgment in the design, conduct, or reporting of research. All investigators, including PD/PIs, co-investigators (including those at other institutions), and other key personnel, must disclose financial conflicts of interest.
FCOI Policy for Investigators
Performing your CNE (or affiliate) role requires exclusive use of your CNE email address. Email retention periods vary considerably for different data types. Both the email retention and record retention and destruction policies are available on Convergepoint (Policy #s CNE-IS-017 & CNE-CC-010) for your review and understanding.
In order for CNE to follow federal and state regulations, all business communications related to your work here, whether reporting findings or anything else related to performing your role as an employee, means that CNE will be the platform for that correspondence. There is a strict prohibition against using your school, faculty, or other email addresses to conduct CNE business.
Additionally, the secure login process to access the CNE platform (including your CNE Outlook account) minimizes risk to sensitive data whether it is Protected Health Information, intellectual property, sensitive information or other communications related to your role.
Please review the policies below sited above and use your CNE email address when emailing CNE related correspondence.
The purpose of the CNE Sanction & Exclusion Screening for Excluded Individuals and Entities Policy (Policy Number CNE-CC-001) “is to ensure compliance with State statutes and the federal Social Security Act, 42 U.S.C. §1128 which require healthcare providers to perform sanction screenings prior to the hire of employees and independent contractors or the engagement of individuals or entities supplying goods or services.”
Sanction screening must be done on all research vendors, collaborators (not employed at CNE), consultants, contractors, CROs, sponsors, or institutions prior to engaging in contract discussion.
**Research participants are considered patients for the purposes of sanction screening and do NOT need to be screened.
Sanction screening will be updated automatically by Compliance Services monthly once an individual or company has been registered with CNE.
Questions about sanction screening can be directed to Barbara Hicks, Compliance & Privacy Coordinator.
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