Frequently Asked Questions

Who does this policy apply to?  Who is a research team member? 
Who is in a position to influence or commit University resources?
What is the difference between actual and potential or perceived conflicts of interest?
When should I fill out a conflict of interest disclosure?
To whom should I submit my conflict of interest disclosure?
Who decides if I have a conflict of interest?
If I have a conflict of interest, can I still take part in the activity?
When is a management plan needed and who drafts it?
Can reviewers delegate the review of conflict of interest disclosures to someone else?
Can the review of my conflict of interest disclosure be expedited?
What is the difference between the Faculty Conflicts Committee and the University Conflicts Committee?
Can my office or department get training on the Conflict of Interest Policy?

Who does this policy apply to?

All University faculty, staff, and students (including full-time and part-time faculty and staff, visiting faculty, postdoctoral scholars, undergraduates, graduate students, postdoctoral fellows and all research team members) who are in a position to influence or commit University resources

Research team members include the principal investigator and any other person who is responsible for the design, conduct or reporting of research.

Who is in a position to influence or commit University resources?

Anyone who can impact decision-making or offer advice on purchasing, hiring, or anything involving University funds or facilities.

What is the difference between actual and potential or perceived conflicts of interest?

An actual Conflict of Interest arises in a situation where financial or other personal or professional considerations compromise an individual’s objectivity, professional judgment, professional integrity, and/or ability to perform his or her responsibilities to the University. Perceived or potential Conflicts of Interest exist in situations where an individual member of the University community, a member of the individual’s family, or a close personal relation has financial interests, personal relationships, or professional associations with an outside individual or organization, such that his or her activities within the University could appear to be biased against the University by that interest or relationship.

When should I fill out a conflict of interest disclosure?

As soon as the situation comes up and before beginning the activity in question. Also, annually, all Members of the University, whether they are engaged in activities that might create the perception of or potential for a Conflict of Interest or not, are required to fill out a Conflict of Interest Disclosure Survey.  An e-mail notifiication will provide instructions when it is time to complete the annual disclosure on line.

To whom should I submit my conflict of interest disclosure?

The new Conflict of Interest Disclosure System automatically forwards your disclosure to the designated reviewer. Please refer to the chart below for the general designation:

Member Reviewer Management Plan Approval
Faculty Dean, Designee, or Faculty Conflicts Committee University Conflicts Committee
Academic Department Chair Dean, Designee, or Faculty Conflicts Committee University Conflicts Committee
Dean Provost or Designee University Conflicts Committee
Staff Department Head or Designee University Conflicts Committee
Staff Department Head, Associate Provost, Vice President, Assoc. Vice President, Athletic Director Supervising Member of the Officers Group or Designee University Conflicts Committee
Provost or Exec. Vice President President or Designee University Conflicts Committee
President Board of Trustees Chair of Board of Trustees
Students Engaged in Sponsored Research Dean or Designee University Conflicts Committee

Who decides if I have a conflict of interest?

Upon receipt of your complete disclosure, your Reviewer will determine whether an actual, potential, or perceived Conflict of Interest exists. If the Reviewer determines that an actual, potential, or perceived Conflict of Interest exists, the Reviewer will make a recommendation to the University Conflicts Committee as to what conditions or restrictions, if any, should be imposed by the University to manage, reduce or eliminate such conflicts. The Reviewer, with input from Member if needed, will draft a Management Plan for submission to the University Conflicts Committee. If further guidance is needed, the Reviewer will consult the University Conflicts Committee before submission.

If I have a conflict of interest, can I still take part in the activity?

You should not take part in the activity until a Management Plan has been approved by the University Conflicts Committee.

When is a management plan needed and who drafts it?

If a Reviewer determines that an actual, potential, or perceived Conflict of Interest exists, the Reviewer, with Member’s input as needed, will draft a Management Plan in order to ensure the reduction, management, or elimination of any conflict. The Management Plan will then need to be approved by the University Conflicts Committee.

Can reviewers delegate the review of conflict of interest disclosures to someone else?

Yes. Reviewers may delegate the review of Conflict of Interest disclosures to an appropriate member of their staff.

Can the review of my conflict of interest disclosure be expedited?

Yes. If you need expedited review of your disclosure due to a deadline or other time constraint, please inform your Reviewer when submitting your disclosure to him or her. If your Reviewer determines that there may be a potential or percieved Conflict of Interest, he or he should request expedited Management Plan review and approval by the Chair of the University Conflicts Committee.

What is the difference between the Faculty Conflicts Committee and the University Conflicts Committee?

The Faculty Conflicts Committee is a group of faculty able to perform, at the discretion of the appropriate Dean, the initial review of a faculty member’s Conflict of Interest disclosure, and draft a proposed Management Plan where needed. The University Conflicts Committee is the group ultimately responsible for final disclosure review, and approval, amendment, or veto of proposed Management Plans.

Can my office or department get training on the Conflict of Interest Policy?

Yes. Please contact the COI Program Manager to set-up a training.