What is Conflict of Interest?
UTMB encourages and supports outside interactions of its faculty and student employees with federal, state, and local governments, and with business and industry as important parts of their research, education, and public service activities.
A Conflict of Interest...
. . . is a situation in which financial or other personal considerations may compromise or have the appearance of compromising an employee's professional judgment in administration, management, teaching, research or any other professional activities.
A Conflict of Interest can occur...
. . . when an opportunity arises to influence UTMB's business decisions, which produces personal financial gain for an academic employee, thus potentially compromising the integrity of decisions they may make as researchers, teachers, and providers of service in consideration of personal financial interests.
. . . when an employee has a significant financial interest in a company that is providing funding for the employee's research or other University activity.
. . . when research directly and significantly affects the financial interest of an employee responsible for the conduct of their research project, and the mere appearance of a conflict of interest can undermine public trust in ways that may not be adequately restored even when the mitigating facts of situation are revealed.
Policy Changes 2012
Applies to ALL research regardless of the funding source.
Changes in the definition of a Covered Individual:
- All faculty engaged in organized research activities.
- Members of institutional research review-related committees.
- Staff members who negotiate or execute research agreements on behalf of UTMB.
- Any individual who, regardless of title or position, is responsible for the design, conduct or reporting of research, including a principal investigator, co-investigator, faculty agent, research tech, research nurse, staff, fellow or administrator who participates in research.
Changes in the definition of Covered Family Member:
- Dependent child or stepchild
- Any other person financially dependent on the Covered Individual
- Any other person with whom the Covered Individual has joint financial interests such that an objective third party could reasonably conclude that the Covered Individual’s decisions or other exercise of professional responsibilities at the institution could be influenced by the effect of that relationship.
New disclosure requirements:
- New NIH threshold = $5,000 (UTMB = $0 threshold for disclosures)
This excludes income from:
- UTMB if currently employed
- Royalties paid by UTMB
- Seminars, lectures, or teaching engagements sponsored by government or institution of higher education
- Advisory committees or review panels for government or institution of higher education
- Mutual funds and retirement accounts for which the investigator does not control the investment decisions
The investigator is required to report “Significant Financial Interest” that reasonably appears to be related to the investigator’s institutional responsibilities:
- Significant Financial Interest (SFI): When a person has more than $5,000 in equity, stock, compensation, etc. from an entity other than his or her employer.
- Payments for service or in-kind benefits for service received, or promised for future payment for any purpose not directly related to the reasonable costs of conducting the Research, as specified in any agreement, that when aggregated equal or exceed $5,000, including:
- salary or other emoluments, excluding UTMB;
- consulting fees;
- honoraria; and
- reimbursement or other payment of travel expenses.
- Intellectual property rights, license agreements, or royalty income of any amount received or had a right to receive.
- Gifts exceeding $250: The value a single gift received in the preceding 12 months that exceeds $250 in value, or multiple gifts from a single entity that in the aggregate exceed $250 in value, other than gifts from a Covered Family Member.
- Reimbursement or income received from fiduciary positions with for-profits or non-profit entities, such as a board member, director, officer, partner, or trustee, held by the Covered Individual or a Covered Family Member.
- Any equity interest in an entity that is publicly-traded if the value, when aggregated for the Covered Individual and Covered Family Members, is $5,000 or more, or equals a one percent or greater share of the entity’s total equity, including a partnership interest, stock or stock options, or other entitlement to such an interest.
- Any equity interest in an entity that is not publicly traded, including a partnership interest, stock or stock options, or other entitlement to such an interest.
Additional Changes in 2012:
- Covered individuals must complete COI Policy training every 4 years.
- Financial Conflicts of Interest information must be made available of a publically accessible website (information available for 3 years).
- Reporting to Public Health Service (PHS) any financial conflict of interest before research funds are spent.
- Expands institutional responsibilities concerning sub-recipient compliance.
What does this mean to you?
- You may not spend grant funds until everyone on the research team has completed training.
- Your grant may not be submitted if we do not have your completed conflict of interest disclosure form on file.
- These regulations apply to all research team members, including those named at a sub-recipient location.
- Your online disclosure must be completed no later than March 1, 2012 at http://rdhs.utmb.edu/
- COI Disclosure Informational Video mms://medtest.utmb.edu/RS/COI/COI_2012.wmv
Contact the COI Office if you have any questions: (409) 266-9435
The University of Texas System
Systemwide Policy UTS175
Disclosure of Significant Financial Interests and Management and Reporting of Financial Conflicts of Interest in Research
Access the 2012 COI Disclosure Form
Due no later than March 1, 2012
Financial Conflict of Interest Information
In accordance with 42 C.F.R. Part 50, Subpart F and UT System Policy, UTS175