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Individual COI

Overview
Research COI
Administrative COI
Travel, Ethics Forms and Paid Authorship

Venn Diagram: Left circle is labeled Financial or Personal Interests. Right circle is labeled Institutional Duties. Intersection is labeled Actual Conflict of Interest, Potential Conflict of Interest, and Appearance of a Conflict of Interest.

Definition and Scope

Conflict of interest relates to situations in which financial or other personal considerations may compromise, may involve the potential for compromising, or may have the appearance of compromising a Covered Individual’s objectivity in meeting University duties or responsibilities, including research activities.

The bias that such conflicts may impart can affect many University duties, including:

  • decisions about personnel,
  • the purchase of equipment and other supplies,
  • the collection, analysis and interpretation of data,
  • the sharing of research results,
  • the choice of research protocols,
  • the use of statistical methods,
  • and the mentoring and judgment of student work.

Details about the information required for COI review are in the Policy on Individual Conflicts of Interest and Commitment.

All faculty, staff, students, trainees are considered Covered Individuals and are subject to the Individual COI Policy for their University duties and activities.

Individual COI may arise in a variety of situations, as detailed in the Policy. Some key areas:

  • Research
  • Intellectual Property Transactions
  • Use of University Resources
  • Gifts to the University for the individual’s benefit
  • Gifts or Favors to Individuals
  • University Review Panels
  • Purchasing or business transactions
  • Administrative Roles

Principles

It is the goal of the Conflict of Interest Office, along with any applicable COI Committees or applicable individuals, to manage any identified conflict in accordance with the following principles:

  • Transparency
  • Honoring the Student/Trainee Experience
  • Protection of the credibility of the individual doing the work

Management

Management of any conflict is determined on a case by case review, specific to the situation. With transparency as essential to COI management, the required foundation is:

  • Public disclosure of the relationships/conflict
    • In any public dissemination, including but not limited to manuscripts, publications, presentations, abstracts, web page, activity sheets.
    • In informed consent documents for any human study. The text is subject to approval by the reviewing IRB.

Other options include:

  • Monitoring
  • Alternative options for trainees
  • Alternative administrative routing and/or recusal

For on-going relationships, a written management plan is sent to the individual with standard terms applicable to the scenario.  This plan serves as the core ethics and foundation of the COI management.  Additional terms are added as applicable in such cases as research studies (see Research section) or if new administrative duties arise.

Confidentiality

The information provided on a COI disclosure is considered part of an individual’s personnel file and is generally not subject to public records requests. Information will be shared with those who have a business need to know the information, such as the Institutional Review Board (IRB) or members of Conflict of Interest Committees.

For certain PHS-funded studies, other guidelines may also apply where the University is required to share the information upon request. Please see sections V. Research H.6(b) and VI. Records Confidentiality and Retention of the University’s Policy on Individual Conflicts of Interest and Commitment.

Disclosure Submission Troubleshooting

If you or any personnel experience technical issues within the AIR system, please call the Office of Research Information Systems (ORIS) help desk at 919-843-2594. Please be prepared to provide as much information as possible to expedite troubleshooting.

Please contact our office if you need help with:

  • Answering any questions on the COI disclosure forms
  • Correcting mistakes on a previously submitted COI disclosure

Consequences of Non-Disclosure

It is a requirement for individuals to disclosure their personal or financial interests as described in the Policy.  The consequences of failing to disclose one’s interests, as they relate to one’s University duties, can vary depending on the circumstances. Please see section VIII. Policy Breaches of the University’s Policy on Individual Conflicts of Interest and Commitment.