Cancer, Cardiovascular Disease, and Pulmonary Disease
Competitive Grants Program

Conflict of Interest Policies and Procedures

• Grant Review Process
• Conflict Matrix Used for Grant Review
• Bylaws Excerpt Regarding Conflicts of Interest
• Guidance from State Statute Regarding Conflicts of Interest
• Review Committee Membership Policies/Guidelines
   
  • Membership Guidelines in Legislation
  • Membership Policy Adopted by CCPD Review Committee
  • List of Members – Contact List

Grant Review Process

Identifying Conflicts of Interest Prior to Grant Review

Before grant applications are distributed to individual Review Committee members for review, Review Committee members fill out and sign a Disclosure of Conflict of Interest form. Review Committee members indicate known conflicts of interest on this form. For instance, if they know that the agency in which they are employed is applying for a grant or if they serve on a Board of Directors for an agency that is applying for a grant. The disclosure form also serves as an affidavit that each Review Committee member will abide by the Colorado Revised Statutes and other state laws including Bribery and Corrupt Influence (§ 18-8-301, et seq., C.R.S.); Abuse of Public Office (§18-8-401, et seq., C.R.S.); the Colorado Procurement Code of Ethics; and the conflicts of interest matrix.

If a Review Committee member has indicated a conflict of interest of any kind on the disclosure form, they will not review that application. Program staff members compile a list of conflicts from these forms to refer to during grant review meetings to ensure that members with a conflict of interest follow the agreed upon procedures.

If a Review Committee member receives an application for review and realizes they have a conflict of interest in reviewing the application, they contact program staff and the application is distributed to other members for review.

The CCPD Review Committee members are also subject to the Colorado Sunshine Law (Open Meetings) (§ 24-6-402, C.R.S.), which does not allow discussion of any grant application (or any other substantive Review Committee business) outside of an official Review Committee meeting, which must be publicly noticed and open to the public.

During Grant Review Meetings

The procedures for conflicts of interest are reviewed at the start of every grant review meeting. When grant applications are discussed at any time during the grant review process, known conflicts of interest with that application are disclosed by staff using a list of conflicts compiled from the conflict forms mentioned above. The Review Committee discusses each known conflict of interest and agrees upon the procedure to be used for that application, following the conflict of interest matrix. Accordingly, members will leave the room for the discussion and vote on the application or will participate in the discussion but leave the room for the vote on the application.

Unexpected Conflicts

There are occasionally conflicts of interest that are disclosed at the last minute, e.g., when a Review Committee member serves on a board of directors for an organization and was unaware that the organization applied for a CCPD grant until the application is brought up for discussion. In this situation, the Review Committee discusses the type of conflict and refers to the conflict matrix to determine if the member may discuss and/or vote on the application.

Review Committee members may also recuse themselves from discussing or voting (or both) on an application due to a perceived conflict of interest. This is at the discretion of the individual Review Committee member if a situation arises in which they have a close personal or professional relationship with an applicant but not, by agreed upon definition, a real conflict of interest.

Conflict Matrix Used for Grant Review

The matrix below is used throughout the grant review process to guide the Review Committee in determining whether a member may discuss an application and/or vote on an application when a conflict of interest exists. This matrix was developed in 2005 when the CCPD Review Committee first convened and is reviewed and revised on an annual basis before each grant cycle begins.

Conflict of Interest Process for CCPD Review Committee

Approved by the Review Committee on November 13, 2009

Type of Conflict	Discuss	Vote
1. Principal investigator	No	No
2. Same organization / involved in application Affiliated with an organization & materially assisted in project development and/or grant application	No	No
3. Same organization / not involved in application Affiliated with an organization & DID NOT materially assist in project development and/or grant application Note:    Ability to vote to be determined by Review Committee after discussion of potential conflict	Yes	No See note
4. Other organization / involved in application Not formally affiliated with an organization but materially assisted in its project development and/or grant application Note:    Ability to discuss to be determined by Review Committee after discussion of potential conflict	No See note	No
5. Direct competitor An institution and/or grant application is in direct competition with another institution and/or grant application in the same disease category or focus area.	No	No
6. Indirect competitor An institution and/or grant application is in indirect competition with another institution and/or grant application in the same disease category or focus area. Note:    Ability to discuss and vote to be determined by Review Committee after discussion of potential conflict	Yes See note	No See note

Bylaws Excerpt Regarding Conflicts of Interest

See complete bylaws

ARTICLE XII:  Conflict of Interest

Section 1.  Where a personal, professional, or financial conflict of interest may exist, participation by members of the Review Committee, including engaging in tasks or duties of the Review Committee, shall be determined under this Section. 

1. A conflict of interest means engagement in an official act or recommendation of the Review Committee which may be influenced by a real or perceived direct economic benefit from an enterprise in which the member has a direct or substantial financial interest.  A conflict of interest may also exist in circumstances where the member has a personal or professional interest that would interfere with participating objectively in an official act or recommendation.
2. A member shall disclose the conflict of interest before the discussion begins or as soon thereafter as the conflict is perceived, and disclose to the Review Committee the basis of the conflict.  The member can then either disqualify him or herself from any further participation or voting on the matter at hand, or upon disclosure of the conflict, the Chairperson will ask for comments from any members or any member of the public present.  Except for the member disclosing the potential conflict of interest, the Review Committee shall vote on whether a conflict of interest exists, and the member disclosing the potential conflict of interest shall be bound by the Review Committee’s vote. 
3. If a conflict is found to exist, the member disclosing the conflict of interest may be disqualified from discussion and/or voting on the matter at hand depending on the degree of conflict of interest. Conflicts of interest may range from a committee member being a principal investigator for a grant application, a writer or key partner in the writing of a grant application, or part of an organization submitting an application and receiving a benefit from the application. 
4. A conflict of interest may also be raised by other Review Committee members or any member of the public in attendance.      
5. Any member wishing to abstain from voting shall notify the Review Committee according to the Review Committee’s procedural policy.
6. Any Review Committee member wishing to disengage from a required task or duty of the Review Committee shall notify the Review Committee and give citation of possible conflict of interest to the Chairperson.
7. Dispensation from voting or duty shall pertain only to the specified vote or duty.

Guidance from State Statute Regarding Conflicts of Interest

Colorado Revised Statutes § 25-20.5-303 (8) states the following:

“If a member of the Review Committee has an immediate personal, private, or financial interest in any matter pending before the Review Committee, the member shall disclose the fact and shall not vote upon such matter.”

Review Committee Membership Policies/Guidelines

Membership Guidelines in Legislation

The members of the CCPD Review Committee are appointed in accordance with the legislation, Colorado Revised Statutes § 25-20.5-303.  The following is the makeup of the committee according to the legislation:

• Director of the Prevention Services Division or the director's designee
• The Executive Director of CDPHE or the executive director's designee
• Three (3) department staff with expertise in cancer, cardiovascular disease, or chronic pulmonary disease, appointed by the Executive Director
• Nine (9) members appointed by the state Board of Health:
   
  • Member of the state board
  • Chronic pulmonary disease professional
  • Cardiovascular disease professional
  • Cancer professional
  • Recognized expert in health disparities
  • Primary care provider
  • Member who represents the rural interest
  • Two public health professionals
• One member of the state senate appointed by the President of the Senate
• One member of the House of Representatives appointed by the Speaker of the House

Membership Policy Adopted by CCPD Review Committee

In October 2008, the CCPD Review Committee adopted the following policy:

“Members on the Review Committee cannot be the Principal Investigator or receive direct salary support through a CCPD-funded grant during their tenure on the committee, beginning with the current members who were appointed with the understanding that they would not be applying for funding, and for all new appointees to the Review Committee.” 

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