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FAQs: Conflict or Bias (COB)

Disclosure and exclusion of conflicts and biases (COBs) ensures and maximizes the quality, objectivity, utility, and integrity of all scientific information disseminated by NIOSH, pursuant to its responsibilities under EEOICPA. Achieving the highest level of scientific information quality is a core value for NIOSH, CDC, and the U.S. Department of Health and Human Services.

It is therefore crucial, for employees and corporate entities that perform any key program function or program support function for NIOSH pursuant to its responsibilities under EEOICPA, to fully disclose all past, current, or planned future employment-related relationships, financial relationships, familial relationships, or supervisory or subordinate work relationships that could pose a COB. If such a COB is found, the individual or corporate entity is to be excluded from performing any key program function.

To find answers to your questions about Conflict or Bias, click any one of the questions listed below to view its answer.

Conflict or Bias (COB)

What does conflict of interest or bias mean?

Conflict or Bias means a potential, actual, or an appearance of a conflict and/or bias between the obligations of a person as a Program employee or contractor, and a personal or corporate interest.

What is the NIOSH Conflict or Bias (COB) Policy?

This document is a Statement of Policy by NIOSH about potential or actual conflicts or biases (COBs) of those persons or entities carrying out responsibilities for the NIOSH Dose Reconstruction Program.

What is the purpose of NIOSH Conflict or Bias (COB) Policy?

Disclosure and exclusion of COB ensures and maximizes the quality, objectivity, utility and integrity of all scientific information disseminated by the Program. Achieving the highest level of scientific information quality is a core value of the President's Office of Management and Budget and the U.S. Department of Health and Human Services.

Thus, it is crucial for Program integrity that each employee and corporate entity performing any key Program function or Program support function disclose fully all past, current or planned future employment-related relationships, financial relationships, familial relationships, or supervisory or subordinate work relationships that could pose a COB.

Who does the NIOSH COB Policy apply?

The COB Policy applies to all persons and corporate entities disseminating scientific information as a part of the NIOSH Dose Reconstruction Program.

Where can I find a copy of the NIOSH COB Policy?

NIOSH's COB Policy Statement is posted and will be updated on the Dose Reconstruction and About DCAS pages of our website.

Please Note: NIOSH reserves the right to amend this COB Policy at any time to take account of changed facts and circumstances.

What is a COB Disclosure Form?

The COB Disclosure Form is a form that must be filled out by each person or entity carrying out responsibilities for the NIOSH Dose Reconstruction Program. The form contains a series of questions designed to assist covered entities in determining whether a COB may exist arising from a past, current or planned employment-related, financial, familial and/or a supervisory relationship.

Where can I find COB Disclosure Statements?

COB Disclosure Statements are located on the Conflict or Bias Policy and Disclosure Statements page on our website.

What happens if a Conflict or Bias is found to exist?

The existence of a COB excludes the individual or corporate entity from performing a key program function associated with a site where a conflict or bias exists. Persons or entities excluded from performing a key program function may perform a program support function after disclosing the conflict or bias.

What is the "NIOSH Policy on the Appearance of Bias for the EEOICPA Program & General Conflict of Interest Requirements" document?

This document summarizes the legal requirements regarding conflicts of interest which apply to NIOSH employees and members of the Advisory Board on Radiation and Worker Health as Federal employees; it also outlines NIOSH's Appearance of Bias Policy regarding participation in activities related to the Energy Employees Occupational Illness Compensation Program Act (EEOICPA).

A copy of this document is located on the Advisory Board Procedures page of our website.

Note: NIOSH is in the process of putting this new policy into operation.

Who do I contact if I have additional questions?

The DCAS conflict of interest point of contact and the NIOSH Conflict or Bias Officer are available to answer questions regarding the NIOSH COB Policy and its implementation.

  • DCAS Conflict of Interest Point of Contact (COI POC)

    Grady Calhoun
    Email: dcas@cdc.gov
    Phone: 513-533-6800 or toll-free at 1-877-222-7570.

  • NIOSH Conflict or Bias Officer

    The NIOSH COB Officer reports directly to the NIOSH Director. He is responsible for ensuring that any key Program function document disseminated by NIOSH conforms substantively and procedurally to all the provisions contained in this COB Policy Statement. In addition, the COB Officer manages the process to ensure that all key Program function documents conform to the NIOSH COB Policy Statement. For example, the COB Officer will review all disclosures; investigate and resolve complaints about failure to disclose; may examine key Program documents for proper attribution; and examine the roles of the document owner, site, and subject experts in key Program documents.

    Frank Hearl
    Email: COBOfficer@cdc.gov
    Phone: toll-free at 1-877-222-7570

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