COI FAQ's

What is conflict of interest?

Conflicts of interest arise naturally from an individual's engagement with the world outside the University. A conflict of interest exists when an employee has an outside interest (usually financial) that affects or appears to affect the individual's professional judgment in carrying out University responsibilities. The outside interest may be directly through the employee or indirectly through others, such as family, or those with whom there are business or other ties. An outside interest is a conflict if: (1) the outside interest may influence the employee's decisions regarding University business or; (2) the outside interest may influence the employee's activities or decisions in teaching, research, and service. The mere existence of a conflict of interest does not imply wrongdoing. Rather, when conflicts of interest do arise, they must be recognized, reported, and either managed or eliminated.

This conflict of interest policy does not address conflicts of commitment, which can occur when external activities of a University employee demand excessive time, conflicting with an employee's responsibilities to the University. The University's policy on conflicts of commitment is set forth in the Faculty Handbook. In summary, the University expects all employees to accord a full professional commitment, in relation to their specific appointment, to the University during the terms of appointment by meeting University obligations first and foremost.

Why does the University need a Conflict of Interest Policy?

It is most important that we know where the boundaries of conflict of interest lie so that we can protect the integrity and academic mission of the University. Furthermore, federal government regulations require us to have a policy and process if we want to maintain federal funding.

What are the benefits to the faculty of a Conflict of Interest Policy?

Conflicts of interest usually arise from a well-intentioned person having two worthy objectives that conflict with one another. The University fulfills its legal obligations and the faculty member is protected when he/she reports the conflict and receives appropriate administrative approval before proceeding. Conflict of interest reporting and management procedures are designed to keep the faculty aware of their conflicts of interest, and then help them to manage, reduce, or eliminate those conflicts.

Why is reporting necessary?

Reporting provides protection for the employee and the institution. Disclosing conflicts of interest, whether real or perceived, and if necessary following a well-defined management plan, mitigates potential risks associated with conflicts of interest. Disclosure protects the validity and objectivity of the product of your scholarship, and preserves the integrity of the University's academic enterprise and business decisions.

Who must report?

All University employees with faculty rank, an employee with graduate student rank who is involved in activities that may result in a conflict of interest, and any unpaid person engaged in teaching, research, scholarship, or service at or on behalf of the University, must report.

Who manages the process for evaluating conflicts of interest?

The Conflict of Interest Officer in cooperation with the Conflict of Interest Committee.

When should my outside interests be disclosed?

• Annually during the reporting process as is guided by your home department.
• Every time circumstances change resulting in a potential conflict of interest.
• During procurement/purchasing, any time you request signatory authority on a University account.
• When submitting a sponsored program proposal (grants/contracts), an IRB application, or an Animal Care and Use Proposal.

What is the process for filing an "Academic Staff Report of Non-University Activities Form?"

Annually you will be directed by your home department to complete and file "Academic Staff Report of Non-University Activities Form." Your unit head and administrative unit will then review the form and send it to the Conflict of Interest Officer. Most faculty will only need to complete the short version of the reporting form.

Why do I have to complete a reporting form yearly if I have no external activities or interests to disclose?

Confirming you have no potential conflicts by completing the "Academic Staff Report of Non-University Activities Form" is itself part of the University's conflict of interest oversight process and key to demonstrating the University's management of potential conflicts.

How long does it take to complete the "Academic Staff Report of Non-University Activities: Short Form" if I have no activities to disclose?

If you have no activities or interests to report, this should take about 10 minutes.

Why do I have to file another "Academic Staff Report of Non-University Activities Form" if I filed one last year?

The University seeks to ensure that each year current disclosures are made for all required filers. It also seeks assurance that there have been no changed circumstances between the time you previously filed a form and the end-of-the-year form.

What happens if there is a conflict?

Conflicts of interest are common and are bound to arise. They are not inherently bad and can exist as long as they can be managed. Many conflicts are properly managed by the simple act of disclosure. Others can be managed with assistance from the Conflict of Interest Committee. For conflicts that cannot be managed, the activity cannot go forward.

What is a "Conflict Management Plan?"

Once a conflict of interest has been identified, the Conflict of Interest Officer will consult with you, your department chair, and the COI committee to design a plan of conditions or restrictions to manage or reduce, or eliminate the conflict.

What about consulting relationships?

Consulting is permissible under the Conflict of Interest Policy, so long as any resulting conflict of interest can be managed appropriately. All consulting must be approved through submission of the "Request for Approval for Outside Employment Form" available through Human Resources.

What are (some of the) potential consequences of non-compliance?

• Loss of faith in the objectivity of academic research.
• Loss of reputation of Oregon State University.
• Loss of ability to receive and manage federal funding.
• Individual or institutional debarment.
• Loss of privilege to serve as PI or co-PI on sponsored proposals.
• Termination of employment.

Where can I get more information on managing conflicts of interest?

By reading the University's Conflict of Interest Policy.

Who should I contact with questions?

coi@oregonstate.edu

 

Thank you to the following universities for allowing Oregon State University to borrow language from their policies and web sites: Case Western Reserve University, Emory University, North Carolina State University, University of Minnesota, University of Pittsburgh, and University of Utah.