Conflict of Interest Review Process

Disclosures and Prior Approval Requests

The Conflict of Interest Office reviews disclosures and prior approval requests to determine if:

  • A conflict of interest exists that unduly influences the discloser's ability to conduct research with transparency and objectivity
  • A conflict of commitment exists that may impede the discloser’s ability to fulfill university obligations or otherwise conflicts with university policies

Ancillary reviews (such as by department chairs or supervisors, the Office of Sponsored Projects or Discovery to Impact) may be required to help the COI Office make a determination. If a real or perceived conflict is identified, the COI Office will work with the filer to develop a plan to manage, reduce or eliminate the conflict. This process may involve the Objectivity in Research Committee, which reviews complex conflict situations and determines appropriate processes for managing or mitigating conflicts. The Committee includes University faculty, associate deans for research, a representative from Legal Affairs and other research administrators involved in technology commercialization and sponsored projects.


Managing Conflicts

Examples of conditions or restrictions that might be imposed to manage financial COI and promote objectivity in research include, but are not limited to:

  • Public disclosure of the financial interest (e.g. when presenting or publishing the research)
  • Disclosure of the financial interest directly to participants in human subjects research
  • Appointment of an independent researcher to protect data integrity and objectivity in research reporting
  • Restricting conflicted research personnel from performing certain aspects of the research to reduce the potential for research bias
  • Requiring a complete copy of original data to be stored in an independently monitored repository

Examples of strategies that might be imposed to manage a conflict of commitment with university responsibilities include, but are not limited to:

  • Limiting the number of hours the discloser devotes to outside activities
  • Stipulating that university resources may not be used to support outside activities
  • Requiring that intellectual property terms be negotiated between the university and an outside entity
  • Appointing a co-advisor for trainees to protect and facilitate progress to degree
  • Restricting the discloser's ability to serve as a principal investigator on university research


Annual Review

All investigators conducting research under a financial COI (FCOI) or conflict of commitment (COC) management plan must meet annually with their department chair or direct supervisor to review their compliance with the requirements of the management plan.

FCOI and COC Management Plan Annual Review Guidance and Checklists


COI and Research Projects

If the financial COI relates to sponsored research, the COI Office will report the managed FCOI as required by agencies that fund the research. Public Health Service (PHS) regulations require the University to make information about managed conflicts of interest related to PHS funded research publicly available upon request. Email these requests to Requests will be responded to within five business days.

Example COI Public Disclosure Statements (DOC)