NIH Conflict of Interest: Recusal Policies for Senior Employees Need Clarification

GAO-07-319 Published: Apr 30, 2007. Publicly Released: May 31, 2007.
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To safeguard the integrity of National Institutes of Health (NIH) research, government employees who have significant decision-making responsibilities and peer reviewers who evaluate the scientific and technical merit of research funding requests should be free from conflicts of interest. One method to resolve a conflict of interest is recusal, which is accomplished by not participating in work that will affect a personal interest or involves a personal relationship. GAO reported on (1) how NIH informs senior employees about recusal and what the requirements are for them to notify supervisors, and (2) how NIH informs peer reviewers about recusal and how NIH monitors their compliance with recusals. GAO reviewed relevant NIH policy manual chapters and NIH guidance and interviewed NIH officials. GAO selected NIH's National Cancer Institute and National Institute of Allergy and Infectious Diseases for the review because they have the largest budgets at NIH.

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Recommendations for Executive Action

Agency Affected Recommendation Status
National Institutes of Health To address the inconsistencies in the policy manual related to senior employees' notification of recusals and ensure that NIH helps its senior employees fulfill their responsibilities related to recusal, the Director of NIH should expeditiously clarify NIH policies with regard to written recusals and supervisor notification related to senior employees' use of recusal to resolve conflicrs of interest.
Closed – Implemented
HHS concurred with our recommendation. As of September 2017, NIH has provided clear instructions and templates on the NIH Ethics Program Web site for written recusal statements when senior employees need to recuse from matters to avoid conflicts of interest. In addition, NIH Ethics staff alerts senior employees to NIH resources on financial disclosure requirements and written recusal statements via email reminders. NIH officials indicated that they consider this recommendation fully implemented. GAO believes that the availability and communication of information on written recusals and supervisor notification meets the intent of the recommendation.

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