Purpose
The purpose of this Policy is to clearly outline the role of CPC Faculty Members from University of Colorado Anschutz Medical Campus (CU Anschutz) and CU Anschutz Affiliates when providing CPC services to clients.
Definitions
CPC: The Colorado Prevention Center d/b/a CPC Clinical Research or CPC Community Health.
CPC Representative: CPC employee or CPC Faculty Member identified by CPC to represent CPC in providing CPC services.
CU Anschutz: Regents of the University of Colorado, a body corporate, for and on behalf of the University of Colorado Denver.
CU Anschutz Affiliates: Affiliates of CU Anschutz including but not limited to Denver Health and Hospital Authority, Children’s Hospital Colorado, and the VA Hospital.
CPC Faculty Member: A CU Anschutz or CU Anschutz Affiliate employee who is listed on CPC’s organization chart and receives salary support from CPC.
Home Institutions: Collectively CU Anschutz and CU Anschutz Affiliates.
CPC Services
All service agreements where a CPC Representative is providing CPC related services shall be between CPC and third party clients. CPC shall identify the appropriate CPC Representative to represent CPC in providing the services. CPC Representative will follow the policies, rules, and regulations of CPC for CPC activities. While performing all non-CPC work or responsibilities, CPC Faculty Members will follow the policies, rules, and regulations of the CPC Faculty Member’s Home Institution.
CPC services primarily relate to new and ongoing clinical trials, clinical research, and community health activities. By providing services on behalf of CPC, CPC Faculty Members are representing CPC as an organization. CPC Faculty Members are expected to direct all service opportunities, including opportunities potentially related to CPC services (e.g. consulting on clinical trial protocols, consulting on investigational product development programs, committee participation, etc.) to CPC for consideration. If a CPC Faculty Member is unsure if a service opportunity is a good fit for CPC, the CPC Faculty Member should still present the opportunity to CPC for consideration. Final determination of what service opportunities are a good fit for CPC will be made by CPC’s Executive Director in consultation with CPC’s Chief Operating Officer and Chief Financial Officer.
Providing services is a part of the CPC Faculty Member’s work activity, and the services are not personal to the CPC Faculty Member. CPC will not separately employ or compensate CPC Faculty Members. CPC Faculty Members agree to not receive personal compensation for any work related to a CPC service or potential CPC service opportunity unless CPC determines the service opportunity is not in CPC’s interest. Service opportunities not related to CPC’s interest may be managed in accordance with the CPC Faculty Member’s Home Institution’s policies.
Salary and Benefit Support
All payments made by third parties for CPC services shall be made to CPC and not to any CPC Faculty Member individually. CPC does not provide payment to CPC Faculty Members directly or provide any other indirect financial payments. Salary and benefit support for CPC Faculty Members activities at CPC are supported through the CPC general fund and processed through the CPC Faculty Member’s Home Institution according to the policies of the Home Institution. CPC will use reasonable efforts to inform all clients that any payment to CPC for services does not directly or indirectly go to the CPC Representative identified in a services agreement. Further, the amount of salary and benefit support of CPC Faculty Members are not determined or influenced in any way by the business opportunities that CPC Faculty Members may present to CPC.
Disclosure Obligations
CPC Faculty Members shall comply with applicable ethics rules, including standards for conflict of interest, disclosure and recusal, of any other professional group including but not limited to medical committees, FDA advisory boards, formulary or pharmacy and therapeutics committees, or any committees associated with the development of treatment protocols or standards, or other medical or scientific organizations.
CPC Faculty Members may conduct public presentations on CPC projects provided that they (i) consult the appropriate CPC employee to check the presentation’s contractual compliance and (ii) disclose the relevant clinical trial sponsor and the CPC Faculty Member’s role in the clinical trial. All CU Anschutz CPC Faculty Members’ participation on CPC projects will be disclosed to CU Anschutz by CPC at least quarterly. For other Home Institutions, disclosures will be made upon request from the CPC Faculty Member.