Conflict of Interest
Conflict of Interest Review & Management
All administrators, faculty, staff, post-doctoral fellows, and students who apply for, receive, or serve as key personnel on a sponsored program must submit a conflict of interest (COI) disclosure questionnaire before proposal submission and at least annually during the period of award. These COI disclosure questionnaires must be submitted through COI-Smart.
The Conflicts of Interest Officer (COI) will review all disclosures in COI-Smart to determine if an identified significant financial interest (SFI) is related to the individual’s institutional responsibilities and has the potential to be categorized as a financial conflict of interest (FCOI). If the COI determines that the SFI is related to the individual’s research, she will work with the individual to draft a Management Plan. The Management Plan is then referred to the COI Review Committee (CIRC) for consideration. During the review process, the COI or CIRC may require the individual to submit more detailed information regarding the SFI and any related project proposed for funding or awarded.
The CIRC will take one of the following actions on each disclosure referred for review:
- Determine that an FCOI DOES NOT exist;
- Determine that an FCOI DOES exist; and
- Require modifications, conditions, or administrative oversight to reduce, eliminate, or manage each conflict for the proposed project in a Management Plan; or
- Require withdrawal of the proposed project.
| Step 1 | Step 2 | Step 3 | Step 4 |
|---|---|---|---|
| Individual discloses SFI and describes how it is or is not related to his/her research | COI considers the disclosure to determine whether the SFI is related to the research and has the potential to be categorized as an FCOI. | If SFI is related to the individual’s research, the COI works with the investigator and administrators from his/her college to draft a Management Plan | COI refers the Management Plan to the CIRC for consideration; CIRC reviews and approves or revises the Management Plan |
Management Plan
The goals of a Management Plan are to ensure open and timely dissemination of research results, protect students, and preserve the objectivity of the research. Examples of conditions or restrictions that may be imposed by a Management Plan include:
- Public disclosure of SFIs (e.g., when presenting or publishing the research);
- For research projects involving human subjects research, disclosure of the FCOI directly to participants;
- Appointment of an independent monitor capable of taking measures to protect the design, conduct, and reporting of the research against bias resulting from the FCOI,
- Modification of the research plan;
- Change of personnel or personnel responsibilities, or disqualification of personnel from participation in all or a portion of the research;
- Reduction or elimination of the financial interest (e.g., sale of an equity interest); and/or
- Severance of relationships that create financial conflicts.