University Conflict of Commitment and Financial Conflict of Interest
The University Conflict of Interest Committee (UCIC) is appointed by the President. The UCIC serves as a University resource with respect to matters involving the general subject of Financial Conflict of Interest and Conflict of Commitment, and in the identification, management, reduction, or elimination of specific inappropriate Financial Conflicts of Interest or Conflict of Commitment. The UCIC shall be chaired by the Vice President for Research or his/her designee, and shall include the Vice President for Academic Affairs, the Vice President for Health Sciences, and the Director of Research Compliance. It shall also include no less than ten faculty members with broad representation across the University, with at least one representative from each of the Schools/Colleges of Engineering, Arts & Sciences, Nursing, Education, Computer & Information Systems, Business and Allied Health, and at least three from the College of Medicine. Appointed committee members shall serve three-year-staggered terms.
Upon referral from a Dean of a School or College, the UCIC shall review all material related to a possible inappropriate Financial Conflict of Interest or Commitment. If the UCIC considers that a Financial Conflict of Interest or Commitment could reasonably appear to damage the credibility or objectivity of the Employees work, it will attempt to resolve the matter by recommending steps to manage, reduce, or eliminate that inappropriate Financial Conflict of Interest or Commitment.
Agreements between clinical investigators and a clinical study sponsor may be reviewed by the UCIC, upon referral by the IRB. The UCIC's determination of any action necessary to manage, reduce, or eliminate an inappropriate Financial Conflict of Interest or Commitment in the proposed clinical study protocol will be returned to the IRB for consideration during its discussion of that protocol. The IRB shall take no action to approve or reject the aforementioned protocol until it receives the recommendation of action from the UCIC.
Conditions or restrictions that may be imposed by the UCIC to manage reduce or eliminate inappropriate Financial Conflicts of Interest or Commitment may include one or more of the following:
- Public disclosure of financial interests
- Monitoring of instruction, research, or service by independent reviewers
- Modification of the instruction, research, or service plan
- Disqualification from participation in an activity that would be affected by a financial interest
- Escrow or divestiture of financial interests
- Severance of the relationship with the Business Enterprise or Entity
- Other remedy as developed by the UCIC
If the UCIC determines that imposing conditions or restrictions on the research of the Employee with the Financial Conflict of Interest or Commitment would be either ineffective or inequitable, and that the potential negative impacts that may arise from a Financial Conflict of Interest or Commitment are outweighed by interests of scientific progress, technology transfer, or the public health and welfare, then the UCIC may allow the research to go forward without imposing such conditions or restrictions.
UCIC review and action on a Financial Conflict of Interest or Commitment referred to it by a School/College Dean or the Institutional Review Board must be accomplished within thirty (30) working days of such referral. A quorum of two thirds of the UCIC must be present to constitute an official meeting to review a Financial Conflict of Interest or Commitment appeal. A majority vote will be required to sustain the imposed condition or restriction or to authorize further conditions or restrictions. Any decision made by the UCIC which concerns faculty tenure or promotion will be referred to the faculty member's respective Vice President.