University Conflict of Commitment and Financial Conflict of Interest
Individual Conflict of Commitment/Financial Conflict of Interest Policy
Institutional Conflict of Interest Policy
Disclosure Forms and Templates
University COI/COC Committee
What is considered a conflict of interest or commitment?
A conflict of interest exists when an employee’s financial or personal considerations may compromise, or have the appearance of compromising, an employee’s personal judgment in administration, management, instruction, research, and other professional and academic activities.
A conflict of commitment exists when professional service or research contracted outside the University interferes with the employee’s paramount obligations to students, colleagues, and the primary missions of the University.
Conflicts of interest, whether actual or perceived, can call into question the integrity of research performed by an investigator at an institution. The mere existence of a Financial Conflict of Interest does not automatically imply any impropriety on the part of the Employee, the University or the Business Entity. Assessing whether a Financial Conflict of Interest is inappropriate and may improperly affect any professional or research activity depends upon the facts of each situation. Therefore, those potential conflicts must be actively identified, monitored and managed to ensure that the University’s endeavors remain, above all, objective and free from bias. The University is an institution of public trust and must maintain maximum levels of public support to carry out its mission. It is the policy of the University that Employees demonstrate in all professional and research activities that their primary obligation is to the University and that they adhere in all instances to the highest standards of ethical behavior.
How does USA identify conflicts of interest or commitment?
The University requires faculty and administrative staff to submit an annual disclosure or as well any new activity on an ad hoc basis in order to eliminate or minimize their impact on any professional or research activity. This policy requires disclosure of all interactions that involve any amount of Financial Interest on the part of each Employee or Employee’s Family as well as of all interactions that could be reasonably perceived to bias any professional or research activity.
Additionally, each and every time an Employee does consulting outside the University with a new entity, the Employee is required to complete and file an External Professional Activities for Pay
form with their department chair or supervisor. Should an excess time commitment beyond the consulting time allowed by the University appear likely, the Employee is required to discuss the conflict of commitment with their department chair or supervisor and develop an acceptable plan of action. The forms will be kept in departmental personnel files.
When does the annual disclosure need to be submitted?
How involved is the annual disclosure process?
By September 30th each fiscal year, as well as any time throughout the year if your circumstances change.
For the majority of employees, it is a simple two page questionnaire that will take less than five minutes to complete.
Varies Types of Disclosures:
Research with Human Subjects
University officers are required to disclose any personal financial interest or commitment (including those of family members) that could give rise to a conflict of interest. The University requires all faculty and administrative officers and staff to complete an annual Financial Conflict of Interest Annual Disclosure
. The disclosure form solicits information concerning outside activities and financial interests as they relate to an individual's scholarly works or research activities and other responsibilities at the University.
Sponsored Project Proposals
Personnel who plan to participate in the design, conduct or reporting of human subject’s research must submit individual, protocol-specific conflict of interest disclosure forms. The Institutional Review Board (IRB) requires a protocol-specific disclosure of any relationships or financial holdings, which could give the appearance of a Financial Conflict of Interest as stated in the IRB application. The Office of Research Compliance has developed a management plan template for use when potential conflicts arise from conducting human subject’s research. In addition, the IRB provides recommended language for conflicts disclosure in informed consent available on the Human Subjects website
. The IRB will take these circumstances into consideration when evaluating the protocol, and will refer any concerns about potential Financial Conflict of Interests or Conflict of Commitment to the Office of Research Compliance and Assurance. These matters may be referred to the University Conflict of Interest Committee (UCIC) and the reporting Employee shall be notified of the referral.
Before any grant application may be submitted by Sponsored Projects Administration, the principal investigator must certify that all individuals listed on the grant do not have a significant financial interest, as defined on the University Transmittal Form. I accordance with federal regulations the term investigator also include spouse and dependent children of the individuals listed. Financial disclosures must be updated during the period of the award, either on an annual basis, or as new reportable significant financial interests are obtained during the life of the award. Potential financial conflicts of interest should be reviewed by the department chair, a management plan composed and forwards the applicant’s confidential packet to the Office of Research Compliance.
What happens if a conflict of interest or commitment is identified?
When a disclosure report appears to constitute an inappropriate Financial Conflict of Interest or Conflict of Commitment, the department chair or supervisor is responsible for determining an appropriate action to address the conflict. If the department chair requires assistance in determining an action to take, the college dean should be consulted.
Are there ramifications of failure to comply?
Failure to submit an annual disclosure or other violations of the Conflict of Interest and Commitment Policy and Procedures, can lead to disciplinary action.
Questions about the Conflict of Interest and Commitment Policy or about the annual disclosure process should be directed to the Office of Research Compliance at 460-6625, firstname.lastname@example.org
or the Office of Vice President for Research at 460-6333, email@example.com
Sponsor Specific Guidelines and Policies
Guidance and Other Reports