Double Trouble in the Lab
A Compliance Case Study
The People:
Dr. Alicia Farr – Researcher and faculty member, VCU School of Dentistry, Founder and CEO of start-up company Dentura
Corinne Jackson – Employee of Dr. Farr’s company Dentura
Trey Lewis – A postdoc research assistant in the School of Dentistry
Amineh Habib – A postdoc research assistant in the School of Dentistry
Ryan Boemer – A student worker in the School of Dentistry offices
The Setting:
An office and a lab in the VCU School of Dentistry
The Event:
Dr. Alicia Farr was holding her weekly team meeting for members of her lab. The research assistants and Ryan, who performed administrative duties for her team, were in attendance. But there was a new face, too.
“Before we get started, I wanted to introduce Corinne Jackson. Corinne comes to us from Medilab and she’ll be working for Dentura, joining me in my research for the Dentura grant.”
“Hello, everyone,” smiled Corinne, “I look forward to working with you.”
“I know I can count on all of you to make her feel welcome. Now,” Dr. Farr continued, “let’s go around the table and share what’s been happening in our experiments this week.”
After the meeting, Trey and Amineh headed out for lunch. As they hit Leigh Street, they were both thinking the same thing. “How is it going to work?” Trey began.
“Well,” replied Amineh, “The best I can come up with is this: Dentura is funded by a research grant, so Dr. Farr will probably be paying Corinne out of those funds, right?”
“Right.”
“So, as long as Corinne only works on the Dentura side of the lab and uses the supplies purchased with Dentura grant funds, it should work. She just can’t work on any of Dr. Farr’s experiments for her VCU research.”
“Again: right. I just see a lot of potential for conflict.”
“Me, too, which is why she had to sign a Conflict Management Plan to disclose potential conflicts when she was approved for the Dentura grant.” Amineh sighed, then said, “Let’s just see how it goes. Dr. Farr has won her share of grants over the years, so I’m sure she knows what she’s doing.”
“Yeah, you’re probably right,” said Trey. “So, are we doing Christopher’s or Leigh Street Cafe?”
A few weeks later, Ryan was sitting at his desk when Corinne walked over with some tiny parcels. “Hi, Ryan! How’s it going?”
“Pretty good for a Monday!”
“Good. Listen, Ryan, I was hoping you could help me. I need to send these samples to one of Dentura’s partners. Can you give me the UPS account number?”
Ryan frowned for a second. “Does Dentura have a UPS account number? Hang on, let me check.”
“Well, no,” Corinne started, “We don’t. Dr. Farr said we need to set that up, but in the meantime, I need to send these ASAP. So, can I have that number?” Ryan hesitated, but since Dr. Farr said to use the VCU account, he wrote the number down on a sticky note and handed it to Corinne.
A few days later, Mail Services stopped by with a stack of boxes from one of the supply companies they ordered from. As he signed for the boxes, Ryan took stock of what was there.
“Here are the gloves and the pipettes. These must be the petri dishes and….and that’s all I ordered. What are the rest of these boxes for?” Ryan examined the labels and noticed that each of them was marked with “Attn: Dentura.” He gathered them up and carried them over to the Dentura side of the lab. As he approached, Corinne smiled.
“Are those for me? Thank you! I’ve been waiting for them.”
“So, when you ordered these, did you use the VCU account? Because they were on the same invoice as the supplies I ordered for VCU.”
“Right,” replied Corinne, “Yes, that’s what I did. Dr. Farr said it just made sense to put them on the same order, since they were coming from the same place; you know, to save on shipping. She said we’d figure out the money later.”
The following week, Amineh and Trey were walking into the lab to start their day. As they entered, they noticed that Corinne was already there, on the VCU side, prepping some slides.
“Good morning!” sang Corinne, “How are you two?’
Amineh and Trey looked at each other, then back at Corinne. “We’re good,” replied Trey, “What are you working on?”
“Well, I hope you don’t mind, but we’re kind of in limbo over in Dentura until we hear back from those partners on the samples. Dr. Farr didn’t want me to lose any hours so she just asked me to set-up some slides for her VCU research.”
“But you don’t work for VCU,” observed Amineh.
“I’m sure it’s fine,” shrugged Corinne, “Dr. Farr wouldn’t have asked me to do it, otherwise.”
Later that day, Amineh and Trey ran into Ryan on the way back from lunch.
“Hey,” began Ryan,”Can I ask you guys about something?”
“Sure,” said Amineh, “What’s up?”
“Well, I don’t understand all the ins and outs of the ways that grants work, but Corinne has been using VCU accounts to send packages and buy supplies. She said Dr. Farr said it’s okay and that she’ll work it out later. I guess she means Dr. Farr will pay back VCU with the Dentura grant money.”
Amineh and Trey exchanged a meaningful look. “Hmmmmmm,” Amineh began, “And this morning, we walked in to find Corinne working in the VCU lab on a VCU experiment for Dr. Farr. But she’s not a VCU employee. She’s a Dentura employee and she gets paid through the Dentura grant.”
“I told you there would be conflicts,” said Trey, “The question is, what should we do about it?”
“Well, I think I’m going to ask about it. I’m worried that I could get in trouble because I gave Corinne the account number and I accepted the packages for both labs from the same invoice,” said Ryan.
“Good point,” said Amineh, “Let us know if you need any help.”
The Takeaway
After Ryan called the ICO, they opened an investigation in conjunction with the School of Dentistry. What they found was evidence that Dr. Farr was using VCU resources, including employees (Ryan), spaces and supplies, and VCU accounts to conduct business for her company Dentura. She was also using a Dentura employee – Corinne – to perform work that should only have been performed by VCU employees. In short, there was a blurring of lines that made it difficult to keep Dentura business “Dentura” and VCU business “VCU.” This situation was the result of a conflict of interest on the part of Dr. Farr; she was focused on the success of her company to the detriment of VCU, and even though there was a Conflict Management Plan in place, she wasn’t following it. It’s not appropriate to use university resources to conduct personal business, even when you intend to “work it out later” by paying the company back out of business – or here, grant – funds. When you have a personal interest that intersects with your VCU role, you must disclose it and work with your supervisor, and if research is involved, the Office of Research Integrity, to create a Conflict Management Plan. Then you must follow it. Had Dr. Farr done this, and shared the details with her team, all parties involved would have understood the rules, sharpening the blurred lines and eliminating the confusion that comes with them.
When you have a personal interest that intersects with your VCU role, you must disclose it and work with your supervisor, and if research is involved, the Office of Research Integrity, to create a Conflict Management Plan. Then you must follow it.
As a result of the investigation, several of the allegations against her were substantiated and Dr. Farr received written counseling for misconduct. VCU also identified the need to educate research faculty who aspire to create start-ups or apply for grant funds to ensure that conflicts are managed early in the process with a Conflict Management Plan the researcher must follow, with consequences for when they don’t. While it’s always important to play by the rules, that’s doubly true when there’s a conflict of interest.
[Please note: Requests to use VCU lab spaces for non-VCU research are almost always denied, not only due to space limitations, but because the potential for this type of conflict exists.]
The names, locations and details of this case study have been changed to protect the identities of the people involved in the actual case.