Policy on Confidentiality, Conflict of Interest and Privacy Issues in Peer and Relevance Review (CCIP)
Policy Guidelines and Implementation Procedures (February 2005)
CCIP Reference Documents:
- CCIP Implementation Guide
- CCIP Policy Guidelines and Implementation Procedures
CCIP Forms:
- Disclosure of Involvement for SD's, GC and Standing Committees Members
- Disclosure of Involvement for IAB members
- Applicant Consent Form for Use and Disclosure of Personal Information Provided to CIHR for Peer Review
Appendices:
- CIHR Rules and Regulations Governing the Conduct of Others
- Confidentiality and Conflict of Interest Agreement and Consent for the Presence of Observers for Peer Review Committee Members
Table of Contents
Introduction
1. Conflict of Interest
1.1 Scientific Directors and Assistant Directors
1.2 Institute Advisory Board Members
1.3 Governing Council and Standing Committees
1.4 CIHR Personnel (Corporate Office)
2. Access to Information and Privacy Acts for the dissemination of information contained in applications
2.1 Applicant Consent
2.2 Internal Dissemination of Applicant Information
2.2.1 Relevance
2.2.2 Institute Priorities and Responsiveness
2.2.3 Multiple Funding Partners
3. Observers of Peer Review Committees
3.1 Consent for the Presence of Observers
3.2 Participation of observers
3.2.1 New Investigators
3.2.2 Funding Partners
3.2.3 Institute Personnel
3.2.4 GC, Standing Committees and IAB Members
3.2.5 Senior Managers
Introduction
In CIHR's unique structure, active researchers are involved in governing, advising on and administering research funds. This involvement of active researchers helps ensure that CIHR is connected to ongoing, leading-edge research and thus better able to maintain a strategic national and international health research presence. It is distinct and worth preserving.
Since its creation in 2000, CIHR has updated its Conflict of Interest (COI) policy to deal with COI and the appearance of COI between CIHR and its many stakeholders. However, neither the current policy, nor the available literature on the subject of peer review in universities and government, offer guidance for the unique challenges raised by CIHR's structure.
In addition, CIHR must meet the requirements of the Access to Information Act and the Privacy Act when releasing information that researchers have entrusted to CIHR in their applications for funding.
In February 2003, CIHR created the Study Committee on Confidentiality, Conflict of Interest and Privacy in Peer and Relevance Issues (CCIP) to examine the legal and ethical checks and balances in place and to make recommendations for implementation. A report was produced in May 2003 and an external consultation was conducted during the summer of 2003. RPPC and SCOGAC approved the recommendations in 2004.
The following document is a shortened version of the full report. It gives the policy guidelines that were approved and the implementation procedures for the use of CIHR stakeholders and personnel.
The procedures will be reviewed within one calendar year of the first open competition in which CCIP is fully implemented.
1.0 Conflict of Interest
1.1 Scientific Directors and Institute Staff with Funding Authority and/or Eligible to Apply for CIHR Funding (hereafter Institute Staff)
Guidelines
In order to comply with the CCIP guidelines, Scientific Directors (SDs) and Institute staff:
- may not apply (as principal investigator, co-principal investigator, co-applicant, collaborator,) to any strategic initiative during their tenure and for one year thereafter;
- must disclose any involvement as researchers in the open competitions to the deputy director responsible for the review committee with a copy to the CIHR Ethics Office;
- will not observe or intervene with the peer review process and committee members for the open competitions and the strategic initiatives except in the following two cases: 1) an SD may communicate prior to the meeting of the committee with members of the Request for Application (RFA) peer review committee or its officers to clarify the purpose and the evaluation criteria for a strategic initiative, and 2) in the case of RFAs in which they have the lead, the SD may provide a list of potential reviewers to the responsible Deputy Director;
- must remove applications to the open competition with which they are associated, from eligibility for any priority announcement competition.
Procedures
1.1.1 Disclosure
- The Disclosure of Involvement in the open competition may be transmitted by e-mail followed by a signed letter or fax to the appropriate Deputy Director with a cc. to the Ethics Office. (See Disclosure of Involvement form);
- Cases of apparent non-disclosure will be brought up to the attention of the Deputy Directors (or Heads in the awards division) who will contact the applicant to ensure that the disclosure is forthcoming;
- Cases of non-compliance with the guidelines will be brought to the attention of the Research Integrity Committee of the Ethics Office as an alleged breach of scientific misconduct.1
1.1.2 Communication with reviewers
- A request for communicating with the peer review committee prior to the peer review meeting to clarify the purpose and the evaluation criteria of a strategic initiative must be made to the appropriate Deputy Director (or Heads in the awards division) in writing at the time of the applications deadlines;
- The Deputy Director (or Heads in the awards division), in consultation with the SD will agree on a time and will organize the communication via teleconference or through a written document to panel officers and/or members;
- The Deputy Director (or Heads in the awards division) will inform the SD of the time and place and participate in the proceedings.
1.1.3 Appointing reviewers to committees that evaluate applications submitted to Institute-sponsored strategic initiatives competitions
- The Deputy Director will provide "Project Titles and Key Words" two weeks after registration deadlines to SDs or RFA lead to assist in identifying potential reviewers, with the option of obtaining anonymous summaries of individual applications upon request;
- The list of names of potential reviewers provided for a strategic initiative and LOIs will be given to the appropriate Deputy Director (or Heads in the awards division) one week following the receipt of the information. The list should include sufficient information about the credentials of those suggested to justify their selection;
- Deputy Directors will share information on evolving peer-review committee composition with the SDs and RFA leads. Because the SDs run the risk of being perceived as coercive since they have decision-making authority over CIHR funding, they should only contact reviewers in exceptional circumstances and after consultation with the Deputy Director;
- The final decision over the composition of the peer review committee rests with the Deputy Directors and their respective Directors.
- In the case of multiple funding partners/Institutes, the RFA team lead will assume the responsibilities for CCIP compliance;
- Cases of apparent interference or undisclosed involvement may be brought to the attention of the lead or SD by the appropriate Deputy Director (or Heads in the awards division) for clarification;
- Cases of non-compliance will be referred to the attention of the Research Integrity Committee of the Ethics Office for adjudication.
1.2 Institute Advisory Board (IAB) Members
Guidelines
In order to comply with the CCIP guidelines, IAB members
- may apply to the strategic initiatives of any Institute as principal investigator, co-principal investigator, co-applicant and collaborator;
- must disclose their involvement to the SD of the Institute when applying to a strategic initiative sponsored or co-sponsored by their Institute;
- must remove themselves from all evaluation (Letter of Intent, responsiveness, relevance, priorization) and funding decisions when they apply to a strategic initiative;
- may not sit as peer reviewers on a strategic initiative sponsored or co-sponsored by their Institute;
- may not observe or intervene with the peer review process and committee members for the open competitions and the strategic initiatives linked to their Institutes.
Procedures
SDs are responsible and accountable for monitoring the exclusion of the IAB members in the decision-making processes.
- The Disclosure of Involvement in an RFA launched or partnered by their Institute may be transmitted by e-mail followed by a signed letter or fax to the SD of the Institute, with cc. to the Ethics Office and to the appropriate Deputy Director (or Heads in the awards division) (See Disclosure of Involvement form);
- SDs will ensure that IAB members who have disclosed their involvement do not participate in any discussions on the strategic initiative in which they are involved (including relevance and/or responsiveness review, evaluation and funding) throughout the duration of funding and subsequent evaluation;
- SDs will ensure that IAB members do not contact peer review committee members for the open or strategic initiatives competitions for the purpose of discussing applications or process;
- Undisclosed involvement may be brought to the attention of the IAB member by the appropriate SD in order to ascertain that disclosure is forthcoming;
- SDs will refer cases of non-compliance to the attention of the Research Integrity Committee of the Ethics Office for adjudication.
1.3 Governing Council Members and Standing Committee Members
Guidelines
In order to comply with CCIP guidelines, Governing Council and Standing Committee members
- must disclose their involvement (principal investigator, co-principal investigator, co-applicant, collaborator, external referee, internal reviewer) in the open and strategic initiatives competitions to the Deputy Director responsible for the peer review committee with a copy to the Integrity in Research Committee of the CIHR Ethics Office;
- cannot serve on peer review committees during and until one year after the termination of their mandate;
- may not observe or intervene with the peer review process and reviewers of the open competitions and the strategic initiatives for the purposes of discussing applications or process.
- SCOGAC members only may observe the peer review process as part of their oversight mandate and interact with committee members during meetings of the review committee. They, however, may not observe a peer review process for any competition in which they have an application (as principal investigator, co-principal investigator, co-applicant, collaborator);
- may not apply to any strategic initiatives in whose development they have been involved;
- may not participate in funding recommendations or decisions at SCOGAC or Governing Council meetings for a competition in which they are associated with an application.
Procedures
- The Secretary to Governing Council will ensure that GC members and Standing Committee members are made aware of the procedures;
- The Disclosure of Involvement in the open competition or in strategic initiatives may be transmitted by e-mail followed by a signed letter or fax to the appropriate Deputy Director with a cc. to the Ethics Office. (See Disclosure of Involvement form);
- Cases of non-disclosure can be brought up to the attention of the appropriate Knowledge Creation Program (KCP) Director who will contact the applicant in order to ascertain that disclosure is forthcoming;
- Cases of non-compliance will be brought to the attention of the attention of the Research Integrity Committee of the Ethics Office for adjudication.
1.4 CIHR Personnel (Corporate Office)
Guidelines
CIHR Vice-Presidents and senior employees, who manage research funding envelopes and are involved in the development and sponsorship of strategic initiatives, may conduct consultative workshops and develop close ties with researchers. In order to comply with CCIP guidelines, and consistent with the limitations for SDs, Vice-Presidents and Senior CIHR managers who direct and manage research funding envelopes and sponsor strategic initiatives:
- must not observe or intervene with the peer review process and reviewers of the strategic initiatives in which they are involved.
Procedures
- Cases of non-compliance will be brought by the Deputy Directors (or Heads in the awards division) to the attention of the Research Integrity Committee of the Ethics Office for adjudication.
2.0 Access to Information and Privacy Acts for the dissemination of information contained in applications
2.1 Applicant Consent
According to the Privacy Act and the Access to Information Act, applicants must be made aware of the use and disclosure of the information contained in their application. Furthermore, the Privacy Commissioner's Office has recently become more insistent that federal granting agencies give a much more explicit description to applicants of the use and disclosure of their information and obtain their informed consent to the dissemination.
Guidelines
Procedures
- CIHR KCP staff will monitor the application modules in order to ensure that the applicant's consent (or non-consent) is respected;
- In cases where the informed consent form has not been filled out, KCP staff will contact the applicant to make sure that it is forthcoming;
- An indication of non-consent does not alter the quality of the peer review. However, applicants are not eligible for priorities announcements and other funding opportunities;
- CIHR KCP staff will ensure that an application where the applicant has refused his/her consent is processed accordingly and will bring the EIS-generated reports (that capture this information) to the attention of the Chair.
2.2 Internal Dissemination of Applicant Information
Guidelines
2.2.1 Relevance/Responsiveness Determination: Information to be shared
a) At assessment stage:
The information necessary to CIHR decision-makers and funding partners at this stage is a LOI or a portion of the registration package that includes the following information:
- Project Title
- Project Summary / or Research Proposal (Registration Package where applicable)
- Anonymized LOI Package (where applicable)
- Abbreviated CV information (LOI Process only and only if stated in the strategic initiatives)
This information is used for conflict of interest determination, relevance review and creation of eligibility pools.
b) At decision stage:
If the abbreviated CV information or any indication of applicant identity was released at the assessment stage, the project title will not be released at the decision stage.
The information necessary to the funding partners at this stage is:
- rank
- rating
- cumulative committee recommended budget
- committee-recommended term
Exceptions where more information may be required must be clearly stated in the original RFA.
A signed, informed consent must be obtained from the applicants before any confidential information is shared with partners / potential partners.
2.2.2 Institute Research Priorities Announcements
a) Information to be shared at the responsiveness stage:
To make determinations of responsiveness, the participating Institute(s) needs the following information:
- project title
- project summary
- completed responsiveness form
(This information to be used for conflict of interest determination and relevance)
b) Information to be shared at the decision stage
To make funding decisions, the participating Institute(s) needs only the following information:
- rank
- rating
- cumulative committee-recommended budget (by funding year and by fiscal year)
- committee-recommended term
Institutes, not involved in the formal research priorities process, that wish to fund highly rated projects not approved in the open competition will be provided with the following information after the peer review process is complete:
- rank
- score
- project title
- suggested CIHR Institute(s), as indicated by the applicant on page 7 of the research module
- committee-recommended budget
2.2.3 Multiple Funding Partners/ Potential for Shared Funding
If funding partnerships are sought at the decision stage, potential partners can determine responsiveness in the same way it was determined by the original Institute(s), by referring to the summaries and responsiveness forms. As with the original Institute(s), responsiveness would need to be determined before the peer review results (merit scores, etc.) are released to the partnering Institute(s).
A document indicating those projects that had been submitted to multiple Institute research priorities competitions for consideration, could also be included in the decision package prepared by the Knowledge Creation Branch, enabling the formation of partnerships.
*No Exceptions*
Procedures
- To ensure consistency throughout CIHR, EIS-generated reports that are CCIP compliant will be made available for all the instances listed above;
- CIHR KCP staff will utilize the EIS-generated reports to transmit the information to the Institutes, funding partners and portfolios;
- At the relevance assessment stage, KCP staff will provide an EIS letter-coded list with project titles and attach manually letter-coded anonymous documentation.
3.0 Observers of Peer Review Committees
3.1 Consent
Guidelines
The Access to Information and the Privacy Acts inform the guidelines and procedures on the presence of observers in peer review committees. In order to comply with CCIP, applicants must indicate their consent (or non-consent) regarding the presence of observers.
The presence of observers is external to the peer review process and tantamount to participatory research. Reviewers are required to give their informed consent (or non-consent) to the presence of observers.
Procedures
- Upon being informed by the peer review coordinator about the refusal to consent, the Deputy Directors (or Heads in the awards division) will inform the Chairs and Scientific Officers;
- The Chairs and the Scientific Officers with the assistance of Deputy Directors (or Heads in the awards division) will monitor the presence of observers during the proceedings;
- Where a reviewer or an applicant has indicated a non-consent to the presence of observers, the Chair of the peer review committee will ask the observer to leave the room.
3.2 Participation of Observers
Guidelines
- CIHR must advise the reviewers of the presence and the rationale, rules and regulations concerning observers;
- CIHR will continue the practice of allowing a maximum of two observers per peer review committee. The final decision will rest with the Deputy Directors (or Heads in the awards division).
- Observers must meet the CIHR eligibility requirements and abide by the CIHR Rules and Regulations Governing the Presence of Observers.
3.2.1 New Investigators
CIHR will create a Committee Member Training Program (CMTP) targeted primarily at new investigators (up to five years of independence) who have never served on a CIHR review panel.
3.2.2 Funding Partner Representatives
It is current practice and tradition at CIHR to have funding partners observe peer review committees. In order to comply with CCIP and observe PRCs, funding partner representatives must
- not have funding decision authority in their organization/agency, etc.;
- sign the CIHR conflict of interest and confidentiality agreement.
3.2.3 Institute Personnel
- SDs and Assistant Directors and any other CIHR personnel who apply to a competition (principal applicant, co-applicant, collaborator) and/or have funding decision-making authority are not allowed to observe peer review committees.
- Institute personnel who are not eligible to apply for CIHR funding and who do not have funding decision capabilities are allowed to observe the peer review committees assessing the applications of strategic initiatives.
3.2.4 Members of Governing Council, Standing Committees (except SCOGAC) and IAB Members
- GC Members and GC standing committee members (except SCOGAC) are not allowed to observe any type of peer review committees.
- SCOGAC members are allowed to observe regularly, provided they are not applicants or in some other conflict of interest situation.
- IAB members are not allowed to observe any type of peer review committees.
3.2.5 CIHR Central Senior Managers
- CIHR Senior Managers - who manage research funding envelopes and design/sponsor strategic initiatives - are not allowed to observe the committees reviewing the initiatives affiliated with their portfolio.
Procedures
- A request to be an observer must be made to the Deputy Directors (or Heads in the awards division) three weeks in advance of the peer review committee meeting;
- The Deputy Directors (or Heads in the awards division) will inform the Chairs and Scientific Officers of the presence of observers and give their names, titles and roles;
- The Deputy Directors (or Heads in the awards division) will review the EIS-generated reports on the consent (or non-consent) of applicants and reviewers and inform the Chairs and Scientific Officers;
- The Chairs and the Scientific Officers with the assistance of Deputy Directors (or Heads in the awards division) will monitor the presence of observers during the proceedings;
- Cases of non compliance will be referred to the attention of the Research Integrity Committee of the Ethics Office.
1 The Ethics Office oversees all questions of integrity in research and acts as an impartial arbitrator.
