Office of Research and Project Administration

SPONSORED PROGRAMS COMPLIANCE

4. Conflict of Interest

Disclosure and Management

Conflicts of interest can be defined as situations in which a divergence between personal and professional interests might be perceived, such that an individual's professional actions might be viewed to be influenced by considerations of personal gain. Conflicts of interest can erode SCIENTIFIC OBJECTIVITY.

In the modern research university, it is impossible to avoid conflicts of interest. The goal of UR's policies in this regard is not, therefore, to eliminate all conflicts but rather to manage them. The key to UR's conflict of interest process is DISCLOSURE.

ALL UR "investigators" are required to submit to their Dean (usually via the Chair or Director) an annual conflict disclosure in accordance with the Faculty Policy on Conflict of Commitment and Interest. Investigator is defined as the PI, Co-PI, or any other person who is responsible for the administration, design, conduct or reporting of sponsored research. In addition, as circumstances may arise during the year, any UR personnel may be required to complete an ad hoc disclosure.

Conflicts of commitment, on the other hand, are situations in which the individual's time and energy are unreasonably diverted away from his or her primary professional allegiance, i.e., away from University responsibilities. Conflicts of commitment are managed in part through limits on the amount of time that a faculty member may consult (see the UR's policy on consulting). Consulting and outside activities can create real benefits for the faculty member and for the institutions involved; they can also create conflicts of commitment, and can precipitate conflicts of interest. In addition to policies governing faculty, UR has related policies for staff.

In addition to UR requirements, two of UR's largest sponsors - the National Science Foundation (NSF) and the National Institutes of Health (NIH) - have their own requirements for PI disclosures whenever a proposal is submitted to either agency. Special attention at the UR is focused on conflicts of interest in BIOMEDICAL research, particularly in the relationships between faculty and pharmaceutical companies in the conduct of clinical trials.

Faculty that conduct clinical trials should note that the level of disclosure of potential financial conflicts is zero. Additional guidance on the management strategies may be found in the URMC Guidelines for Managing Faculty Financial Conflict of Interest: Clinical Trials.

Any issues related to conflict of interest should be discussed with your Chair or School Dean. The University's Conflict of Interest Committee is an advisory body that can assist both faculty and academic leaders recommending appropriate steps to help to manage and mitigate conflict. The School of Medicine and Dentistry has its own advisory commitee to the Dean, the Confilct of Interest Advisory group. The offices of the ORPA and of OTT are also available to provide advice and assist in the preparation of conflict management plans.