An Overview of Conflicts of Interest

Outline

Background

Reporting

Why

Examples

Who and how

Review and report form

Management of conflicts

Background

• “A conflict of interest may occur when an employee is in a position to make a decision in his or her capacity as a university employee that may result in personal or family gain, financial or otherwise.” - OSU Policy
• “As the university prompts and encourages new and varied collaboration, it is a natural by-product that relationships can become tangled, regardless of whether this is the case.” - OSU Policy

 

Reporting--Why

• Provide protections for employee and university
• Disclosing real or perceived conflicts provides mitigation of potential risks associated when operating with two competing interests
• Protects the validating and objectivity of the product of your research by not raising questions about an employee’s ability to make independent decisions when presented with competing interests
• Preserves the integrity of the academy through self-regulation

Consequences of Non-Compliance

• Loss of faith in the objectivity of academic research universally
• Loss of reputation of OSU
• Loss of ability to receive and manage federal funds
• Individual or institutional debarment
• Loss of privilege to serve as PI or co-PI on grant applications
• Termination of employment
• Civil fines under Oregon law

Real or Perceived COI Problems

• Loss of objectivity
• Self dealing
• Multiple pay for one job
• Conflicting official obligations
• Use of institutional facilities/resources (for personal gain)
• Misuse of confidential information
• Nepotism
• Inappropriate decisions with students

Common Situations to Report

• Simultaneous consulting relationships with management role, or equity holdings in outside organization sponsoring investigator’s research
• Ownership interest in the technology that is the subject of one’s research

Common Situations to Report

• Dual supervisory roles, e.g. researcher is supervising the same students as employees of his/her company and as faculty mentor
• Subcontract or other direction of university resources to a company in which investigator has an interest

Who Must Disclose Via this Policy

• Employees with faculty rank
• Employees with graduate rank
  • Graduate teaching assistants
  • Graduate research assistants
  • Fellows
• Any unpaid person engaged in teaching, research, scholarship, service, at or on behalf of OSU
  • Courtesy
  • Affiliate
  • Visiting
  • Clinical
  • Resident

When and How to Disclose

• When
  • Annually
  • Whenever circumstances change

• How
  • Department/college will guide process
  • Short form:
    • Majority of people
    • 10 minutes effort
• Long form:
  • For those with potential conflicts
  • 20 minutes effort

Disclosure Form

• Academic Staff Report of Non-University Activities: Short Form

Report Forms

• Your signature certifies all real or perceived conflicts, if any, are reported
• Unit head and college certifies review for completeness and accuracy

Review Process

• Conflict of Interest Committee/COI Officer review situations
• COI Officer/Committee renders reasonable judgment as to whether the financial interests reported could directly and significantly affect the design, conduct, or reporting of the proposed project

Management Strategies

• Disclosure
• Reduction
• Elimination
• Disclose
  • Disclose financial interest to public
  • Access to data, materials, open publications of results

Management Strategies

• Reduction
  • Modify research plan or scope of activity
  • Verify research results by independent reviewers
  • Limit participation of students, human subjects; provide special protections for students
  • Create oversight committee to monitor situation
  • Abstain from promotional decisions for staff

• Eliminate
  • Disqualify from participation in all or part of research
  • Remove from financial aspect of project
  • Remove purchasing authority
  • Take a leave of absence with or without pay
  • Sever relationships that create actual or potential conflict
  • Divest all or part of financial interest

COI Resources

• For more information about Conflicts of Interest see the OSU COI webpage at:
• http://oregonstate.edu/research/osprc/rc/conflictofinterest.htm