Sponsored Program 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 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. Study coordinators are defined as investigators. In addition, UR investigators are required to complete an ad hoc disclosure within 30 days of acquiring a new significant financial interst.

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.

Faculty that conduct clinical trials should note that the level of disclosure of financial interests is zero. In other words, all investigator financial interests related to a company sponsoring the clinical trial must be disclosed to study subjects and staff. 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 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 ORPA and of Office of Counsel are also available to provide advice and assist in the preparation of conflict management plans.