Conflict of Interest Summary
- Introduction
- The Importance of Disclosure and Management
- How to Avoid or Minimize Conflicts of Interest
Introduction
In order to expand the relevance, applicability and dissemination of research, the University of California encourages faculty to interact with entities outside of the university that sometimes give rise to financial conflicts of interest. Conflict of Interest is best described as a convergence of an investigator's private interests with his or her research interests, such that an independent observer might reasonably question whether the investigator's professional actions or decisions are improperly influenced by considerations of personal financial gain. These interests most often relate to income, loans or gifts to the individual; and ownership, investments or positions held by the individual. This differs from Conflict of Commitment, which refers to a conflict of time and effort allotted to University activities.
UC's general policy on conflict of interest is that none of its faculty, staff, managers, or officials shall engage in any activities that place them in a conflict of interest between their official activities and any other interest or obligation. The policy related to research activities extends to the investigator's spouse and dependent children, but other policies related to purchasing decision-making extend to siblings, parents and in laws. As a recipient of State and Federal funding, the University of California has established policies and guidance documents for research and administrative activities in order to protect this public trust.
The Importance of Disclosure and Management
Many financial interests are insignificant and unlikely to bias an investigator's professional decisions, however, it is important to seek an independent judgment of the facts. Financial interests can be deemed acceptable and research allowed to proceed by disclosing the interest to the University Conflict of Interest Oversight Committee (COIOC).
When an investigator has larger or multi-faceted financial interests, conflict of interest management is the key. The COIOC reviews the investigator's disclosure and recommends one or more of the following options: reduction or elimination of financial interests; periodic progress reports; education of research personnel; monitoring by a third party or ad hoc committee; disclosure of financial interests to journal editors and in presentations; and disclosure to human subjects. The Vice Chancellor for Research makes the final decision based upon the Committee's recommendation.
The Vice Chancellor for Research may determine that some relationships cannot be managed, when the investigator's private interests are inextricably linked to his or her university research interests in a way that presents a real or perceived conflict of interest that cannot be addressed by the above options.
How to Avoid or Minimize Conflicts of Interest
One could avoid conflict of interest by foregoing all income, investments, loans, or positions related to an outside entity. It is more realistic, however, to consider the COI: Guidance to Principal Investigators for Disclosure and Review of Financial Interest in Non-Governmental Sponsors of Research and COI: Guidance for Clinical Investigators in structuring a balance between personal and research interests. Individual questions regarding financial interests can be directed to Bruce Morgan, Assistant Vice Chancellor for Research, or Cathryn Lucas, Conflict of Interest Administrator.
