The Albany Med Health System (“System”, “Albany Med”, “AMHS”) Board of Directors has adopted a Conflict of Interest (“COI”) Policy and procedure to insure all Individuals acting on behalf of AMHS do so in the interest of the System, its affiliated entities, patients, students, and research subjects unaffected by personal financial interests or opportunities.
A potential COI may exist when an individual, acting on behalf of an Albany Med Health System entity, has outside interests or relationships where self-interest or the potential for personal benefit may bias or interfere with their decisions and actions on behalf of the System.
Potential conflicts of interest include situations where relationships have been created; may be created in the future; or by virtue of an Individual's role with the System, may create the impression that a conflict of interest exists. Each Individual is expected to disclose all potential conflicts of interest for themselves and on behalf of members of their immediate family.
The AMHS Conflict of Interest Policy governs the disclosure, resolution and reporting of all potential COI.
All Individuals, paid or volunteer, are required to comply with this policy and related procedures in order to be authorized to act on behalf of the System or an affiliate.
Reporting a Potential Conflict of Interest:
Those Individuals required to complete an annual disclosure will be sent, via email, a personal link to the COI Disclosure Form upon appointment and annually thereafter. This link is unique to each Individual and should not be forwarded or shared. This link will allow the respondent to leave and return to the form before submitting it.
Those individuals who suspect they may have a potential COI should report it as soon as possible utilizing the appropriate form:
- Complete the COI Disclosure Form if you have not completed the COI Disclosure Form for AMHS within the preceding 12 months. If using the link on this web page, the respondent must complete the form and submit it in one session. Alternatively, the respondent can contact Corporate Compliance and Audit to obtain a personalized link to the COI Disclosure Form which will allow the respondent to leave and return to the form before submitting it.
- Complete the COI Change of Circumstance Form if you have completed COI Disclosure Form for AMHS within the preceding 12 months and you would like to update information already submitted. This will notify Corporate Compliance and Audit of a role or position change, an update due to proposed or funded research, a potential COI or related party transaction that was not identified in the previous submission, or a change in circumstance related to an item already submitted (e.g., change in fair market value). This form should be completed and submitted within 15 days of the change in facts or circumstance. This form must be completed and submitted in one session.
The following documents will facilitate completion of the COI Disclosure Form and the COI Change of Circumstance Form:
COI Change in Circumstance Questions
Additional Note for Faculty:
Faculty contracts typically require Faculty to report royalty, honoraria, or other professionally related payments on an annual basis, when the total of such payments in a year exceeds 5% of their annual salary. Events of this nature should be disclosed to Corporate Compliance and Audit via the COI Disclosure process. Corporate Compliance and Audit will forward information related to these conflicts to the applicable department chair and the Dean, Albany Medical College.
Any support from commercial entities should be supported by a written agreement, documenting all terms, conditions, and purposes of the agreement, with compensation determined at fair market value, and disclosed to your Department Chair in advance of your participation.
If issues arise that you feel may create a potential conflict of interest, you should consult with Corporate Compliance and Audit before proceeding.
Corporate Compliance and Audit