Conflict of Interest Resolution Strategy
To uphold transparency and fairness, the CRC maintains a conflict-of-interest policy for all funding decisions.
Purpose
This page defines a complete Conflict of Interest (COI) resolution strategy tailored to the Washington State University (WSU) Cannabis Research Center (CRC) co-directors (Dr. Carrie Cuttler and Dr. Ryan McLaughlin), as well as the Internal Scientific Advisory Committee (ISAC). It operationalizes procedures described in the CRC 2025 Strategic Plan and aligns with WSU COI and nepotism policies. The goal is to identify actual, potential, and perceived conflicts and to implement measurable, auditable steps to mitigate them while preserving the CRC’s mission and leadership continuity.
Executive Summary
Drs. Cuttler and McLaughlin are both active cannabis researchers at WSU (clinical and preclinical expertise, respectively). This overlap combined with their marital relationship can create actual, potential, or perceived COIs around resource allocation, grant review, student awards, and external partnerships. Additionally, members of the CRC ISAC Committee frequently submit proposals to CRC funding calls for faculty, graduate student, and travel awards that could pose a potential conflict of interest. This COI strategy uses (1) mandatory disclosures and recusal rules, (2) separation of duties and paired signatories, (3) external peer review and ISAC oversight (already in the CRC Strategic Plan), (4) audit and reporting, and (5) transparent communications to manage and resolve COIs.
Identification of Potential Areas of Conflict
- Faculty pilot grant review/selection
- Graduate student summer research grant and travel award review/selection
- Financial support for license fees and open access fees
Core Mitigation Measures (Operational Procedures)
Mandatory Disclosure and Documentation: Both co-directors and ISAC members will file and maintain current WSU COI disclosures (Form SFI) and keep disclosures updated within 30 days of any new potential SFI or activity that could produce a COI. For public transparency, the CRC webpage section will summarize COI management procedures and list CRC awards and recipients to increase public accountability.
Mandatory Recusal Rules: A co-director or ISAC member must recuse themselves from all discussions, reviews, decisions, or signoffs that directly affect them, members of their lab, or (in the case of a co-director) the other co-director. This includes award recommendations, committee appointments, and financial approvals. Recused co-directors and ISAC members are prohibited from drafting recommendation language, editing decision memos, or influencing committee members in those specific matters.
Paired Signatory Authority: Financial approvals and disbursement of CRC funds that benefit either co-director or their labs (or members thereof) require dual signoff: an Administrative Advisory Committee signatory (or Office of Research rep) PLUS the ISAC. No single co-director may unilaterally release funds to the other codirector or their lab.
External Peer Review and Blinded Scoring Procedures: CRC faculty pilot awards and graduate student summer research awards will undergo external peer review with reviewers approved by members of the ISAC Committee. Reviewers must declare conflicts and reviewers with close personal relationships with applicants are excluded.
Escalation, Monitoring, and Enforcement
A. Escalation Pathway
Level 1: ISAC review — items where recusal leaves insufficient internal decision-makers will be referred to ISAC. If the situation involves a member of the ISAC, that individual will recuse themselves from discussion regarding the item.
Level 2: Administrative Advisory Committee — for operational or financial disputes and matters with potential institutional implications.
Level 3: Office of Research & HR — final determinations on significant COI incidents, nepotism concerns, or disciplinary matters will be made in accordance with WSU policies (EP27, BPPM 60.14).
B. Monitoring and Audit
Administrative Audit: The Office of Research will conduct a review of COI compliance including disclosure updates, award decisions, and financial signoffs.
Annual COI Summary in CRC Report: The CRC annual report will contain a COI section listing any disclosures filed, recusals taken, grants to co-directors, ISAC members, or their labs (with independent confirmation from external reviewers), and any COI incidents and resolutions.
C. Remedies for Violations
Corrective Actions: If a breach is found (e.g., undisclosed COI or improper approval), actions may include re-review of decisions, reallocation of funds, additional oversight, or referral to HR.
Transparency: Any significant COI incident and remediation steps will be summarized in the CRC annual report and shared with the Office of Research.
Templates, Tools, and Record Keeping
To operationalize this strategy, CRC will maintain standardized templates and records:
COI Disclosure Tracking Form (internal): date of WSU disclosure, last update, and SFI details.
COI Recusal Log: meeting/minute entry with date, agenda item, who recused, and reason.
External Reviewer Selection Log: reviewer names, affiliations, declared conflicts, and exclusion reasons.
Blinded Scoring Record & Rubric: archived for each competition.
Dual Signatory Approval Form: for financial disbursements benefiting co-directors or their labs.
Operational Examples / “Floor Rules”
These examples are immediate, enforceable rules:
Flagging: Any application where a co-director, ISAC member, or their student serves as PI, key personnel, or applicant will be automatically flagged and routed to external review; both co-directors (in the case of a COI involving a co-director) or ISAC member (in the case of a COI involving an ISAC member) will be prohibited from reviewing or accessing reviewer identities/scores prior to ISAC administrative verification.
Dual sign-off for funds: Travel, license fees, or open access publication support where the beneficiary is a co-director, ISAC member, or a student from a co-director or ISAC member’s lab will require signatures from (a) ISAC chair AND (b) Administrative Advisory Committee signatory or Office of Research representative.
Student awards: Applicants who are current/prospective lab members of either codirector or a current ISAC member must be evaluated by external reviewers (student summer research awards) and/or an ISAC (graduate student travel awards) excluding both co-directors (in the case of a COI involving either co-director) or the ISAC member (in the case of a COI involving an IASC member).