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Research Conflict of Interest

Research Conflict of Interest form

The Research Conflict of Interest Policy  is to educate faculty about disclosure requirements, to provide information about how conflicts of interest are assessed, if necessary, how to manage those conflicts, and to promote objectivity in research. All proposed, awarded and ongoing UNTHSC research projects shall not be biased by any significant financial interest of any health science center investigator responsible for the design, conduct or reporting of that research project. This applies to all UNTHSC Faculty Members-Investigators who apply to federal agencies for and/or conduct research projects funded by federal agencies. A faculty member is considered to have a potential conflict of interest when he/she, any of his/her family, or any associated entity possesses significant financial interest in any activity that involves the faculty member's responsibilities as a member of the UNTHSC faculty. Included in these responsibilities are all activities in which the faculty member is engaged in the areas of teaching, research, patient care, and administration. All Faculty Member-Investigators are required to submit a Statement of Interest Form / Potential Conflict of Interest Disclosure Form to the Office of Research and update the Statement(s) as changes occur.

The purpose of this policy is to educate faculty about disclosure requirements, and to provide information about how conflicts of interest are assessed, and if necessary, how to manage those conflicts.

Conflicts of interest are generally defined as those situations in which an individual’s financial, professional, or other personal considerations may directly or indirectly affect, or have the appearance of affecting, an individual’s professional judgment in exercising their institutional duty or research. A conflict of commitment refers to a situation where an individual engages in external activities, either paid or unpaid, that interferes with their primary obligation and commitment to the institution.

While most disclosures of financial interests will probably be deemed not significant conflicts of interest, financial interests above certain thresholds will automatically be deemed significant conflicts of interest and will require closer scrutiny and possible elimination, mitigation, and/or management.  The thresholds are as follows:

A. Interests over $10,000 in monetary value.

B. (1) These interests involve the ownership or promise of stock or stock options over $10,000 or 0.5% of the total value of the company, in a publicly traded company.
    (2). These interests involve the ownership or promise of stock or stock options of any amount in a privately-held or start-up company.  

C. An individual serves in a consulting or other fiduciary role for a financially interested company, whether or not remuneration is received.

Disclosures of financial interests above these thresholds will be reviewed by the Research Conflict of Interest Committee (COIC) to determine if the financial interests or relationships are significant enough to create the perception of, or actual potential for bias or compromise the objectivity of the research, potentially harm a subject in the study, provide the company early or exclusive access to research results, constitute an inappropriate use of university resources and facilities, restrict the freedom to publish or publicly disseminate research results, compromise academic freedom--particularly of students or other trainees, create the opportunity to exploit or coerce students, trainees, faculty who work within their divisions, or others supervised by the conflicted investigator, or inhibit the fair licensing of intellectual property.  Such conflicts of interest should be referred to the Research Conflict of Interest Committee in order to determine what steps might be needed to eliminate, mitigate or manage the conflict.

 NOTE: All personal financial interests related to UNTHSC activities must be reported, regardless of dollar amount. All reported financial interest will be reviewed by the Research Conflict of Interest Committee in order to determine if a significant conflict of interest exists. If needed, the Committe will determine what steps are needed to eliminate, mitigate, or manage the conflict(s).

Eliminating, Mitigating, or Managing Conflicts of Interest

Conflicts that are deemed to have the potential or are likely to be perceived as having the potential to have a direct or indirect affect, or have the appearance of affecting, an individual’s professional judgment in exercising their institutional duty or research must be eliminated, mitigated, or managed. Such strategies for eliminating, mitigating, or managing conflicts can include:

  • development of management plan
  • public disclosure of significant financial interests;
  • training on conflicts of interest and commitment for all personnel involved in the research;
  • monitoring of research by independent reviewers;
  • modification of the research plan;
  • disqualification from participation in all or a portion of the research;
  • divestiture of significant financial interests; and/or
  • severance of relationships that create actual or potential conflicts

The Research Conflict of Interest Committee will make this determination and assist in deciding which steps are necessary for managing the conflict or conflicts.

Outside professional relationships, can result in conflicts regarding time and energies which represent conflicts of commitment:

Such conflicts of interest should be referred to the Research Conflict of Interest Committee in order to determine what steps might be needed to eliminate, mitigate or manage the conflict.

NIH-Financial Conflict of Interest (FCOI) Tutorial - Investigators (those responsible for the design, performance, or reporting of research). A printable certificate is provided upon completion for your records.

 


This page last updated May 07, 2012
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