Artificial Intelligence and Technology Collaboratories (AITC) Conflict of Interest Policy

Purpose and Scope

This policy establishes standards for identifying, disclosing, and managing conflicts of interest in the review of applications to the AITC. Its purpose is to ensure that applications are evaluated fairly and objectively, and that review and funding decisions are free from real or apparent conflicts of interest. The policy is modeled on the principles NIH applies to peer review (42 CFR Part 52h) and applies uniformly to participating AITCs and to individuals involved in the review process.

Definitions

• Reviewer: Anyone who scores, discusses, ranks, or recommends applications for funding at any stage of the review process. This includes AITC review officials.
• AITC review officials: The AITC program leaders each AITC designates with authority to decide which applications advance at each review stage, and which are recommended to NIA for funding. Individuals whose role is solely administrative are not AITC review officials.
• Review process: All stages of the competition: LOI review, LOI deliberation and ranking, full application review, full application deliberation and ranking, and recommendations to NIA.
• Major role: Anyone named on the application as PI, multi-PI, co-investigator, other key personnel, or other significant contributor.
• Primary appointment: A person’s main faculty or employment appointment.

Section 1. Not Eligible to Review

A proposed reviewer may NOT participate in the AITC’s review process if:

• The reviewer is named on an application as a Principal Investigator (PI) or multi-PI (MPI) to that AITC in the current competition cycle.¹
• The reviewer (or immediate family member) would receive a direct financial benefit if an application to that AITC is funded.¹
• The reviewer is a member of the National Advisory Council on Aging (NACA).²

Notes:

1. The reviewer may not review any application in that AITC’s pool but may serve as a reviewer for other AITCs.
2. The reviewer may not serve as a reviewer for any AITC in the current competition cycle.

Section 2. Conflicts Requiring Recusal

Proposed reviewers MAY participate in the AITC’s review process, but must recuse themselves from specific applications when:

• The reviewer has a primary appointment in the same department, division, or center as the PI or anyone else on the application with a major role, as determined by the AITC based on its institutional structure.
• The reviewer is named on an application as a co-investigator (co-I), or in any other non-PI role (e.g., technical advisor, subject matter expert), and/or the reviewer has provided or intends to provide technical assistance related to the application.
• Within the past three years, the reviewer has collaborated with, prepared a grant application or contract proposal with, or had another professional relationship (such as mentoring) with anyone on the application who has a major role.
• The application includes a letter of collaboration or comparable letter from the reviewer.
• The reviewer serves as a member of the advisory board for the project under review.
• The reviewer has an indirect financial interest from the applicant institution or PI of over $10,000 in honoraria, stocks, and fees during the last year or during the project period.

Recusal applies only to the conflicted application. The reviewer may continue to participate in review, deliberation, and ranking of all other applications.