Conflict of Interest
Frequently Asked Questions
- What is a Conflict of Interest?
- What is a Conflict of Commitment?
- What is a Significant Financial Interest?
- What is the purpose of and annual Conflict of Interest Reporting and any subsequent updates?
- Who is required to file a Conflict of Interest Report?
- Who is considered Family for reporting purposes?
- What must be reported and when?
- What is the difference between Annual Reporting and the IRB Form X?
- Do I have to complete the report even if I have no activities to disclose or if my interests are less than amounts as defined in “significant financial interest?
- For reporting purposes, what is compensation? For example, does it include reimbursement for travel expenses for consultations/advisory board meetings?
- Is there a dollar limit that I can receive annually in honoraria and consulting fees?
- Is there a time limitation on outside activities?
What is a Conflict of Interest?
The term “Conflict of Interest” refers to situations where the individual has the opportunity to influence the Health Science Center’s business, administrative, academic, research, clinical, or other decisions in ways that could lead to personal financial gain or advantage or could cause to appear to cause bias in the design, conduct, or reporting of research or educational activities.
What is a Conflict of Commitment?
The term “Conflict of Commitment” refers to situations where the individual undertakes external commitments that burden, interfere with, or detract from the member’s primary obligations and commitments to the Health Science Center.
What is a Significant Financial Interest?
A “Significant Financial Interest” is anything of monetary value and includes, but is not limited to: salary or other payments for services (e.g., consulting fees or honoraria): equity interests (e.g., stocks, stock options or other ownership interests); and intellectual property rights (e.g., patents, copyrights, and royalties from such rights.) This includes:
- salaries, royalties, paid authorship, or other payments for services if, when aggregated for the individual and family, is expected to equal or exceed $5,000 from any single source for any 12-month period;
- equity interest including stock, stock options, or other ownership interest or entitlement to such interest, valued by reference to public prices or other reasonable measures of fair market value, if, when aggregated for the individual and family, equals or exceeds $5,000 in value as determined by reference to public prices or other reasonable measures of fair market value.
- for the purposes of research involving human research participants, any amount as defined above must be included in the Conflict of Interest Report (Form X) to the IRB as part of the IRB protocol submission.
What is the purpose of the annual Conflict of Interest reporting and any subsequent updates?
Annual reporting and updates when required satisfies the requirements of various Health Science Center, UT System, State of Texas, and federal policies regarding reporting (disclosing) external activities and interests and allows the Health Science Center to determine whether the individual’s activities and interests are consistent with policy requirements and to take actions, if necessary, to manage real, potential, or perceived conflicts of interest or commitments.
Who is required to file a Conflict of Interest report?
- any faculty member who is compensated by the Health Science Center and who holds an academic appointment
- any other individuals who are responsible for the design, conduct, or reporting of research activities such as postdoctoral fellows, other scientists, study coordinators, and the like
- any administrative/professional staff member who is authorized to execute contracts on behalf of the Health Science Center or who makes the final decision (exercises discretion) with regard to the award of contracts or other financial transactions; these individuals are typically individuals who have project ids (accounts) in their name, academic administrators, or certain central office administrative or professional staff
Who is considered Family for reporting purposes?
For reporting purposes, family is any spouse, dependent child or stepchild, any other person financially dependent on the individual making the report, and any other person with whom the reporting individual has joint financial interests such that an objective third party could reasonably conclude that the reporting individual’s decisions or other exercise of professional responsibilities at the Health Science Center could be influenced by the effect of that action on the person’s financial interest. Any individual may be identified as family without regard to whether a legal or biological relationships exists with the reporting individual.
What must be reported and when?
The individual is expected to report all of their outside activities as well as those holdings or activities which meet the definition of Significant Financial Interest. Reporting is completed on an annual basis through the Health Science Center’s eCOI system and should be updated if significant changes occur prior to the next annual reporting period.
What is the difference between the Conflict of Interest annual report and the IRB Form X?
The COI Annual Report and any updates covers all of the reporting individual’s external activities and interests. The IRB Form X, completed at the time of IRB protocol submission, covers only the individual’s external activities and interests relating to the specific protocol regardless of the amount of compensation or interests in the external sponsor; in other words, Form X requires information that is relevant to one activity; the COI Annual Report covers everything.
Do I have to complete the report even if I have no activities to disclose or if my interests are less than amounts as defined in “significant financial interest?
Yes. The Annual Report requires not only information regarding Significant Financial Interests, but also requires information concerning any external compensated or uncompensated professional activities or interests as well as an individual’s service on no-profit boards or receipt of gifts.
For reporting purposes, what is compensation? For example, does it include reimbursement for travel expenses for consultations/advisory board meetings?
Compensation includes personal income, honoraria, and consulting service fees that are received from sources outside the Health Science Center. At this time, it does not include reimbursement for travel expenses.
Is there a dollar limit that I can receive annually in honoraria and consulting fees?
The aggregate of all compensated outside professional activities may not exceed 30% annually of the individual’s Health Science Center institutional base salary (assuming the individual is full-time at the Health Science Center).
Is there a time limitation on outside activities?
A full-time faculty member may engage in compensated and uncompensated outside professional activities no more than a cumulative average of four days per month during the calendar year; these days may not be carried forward from year to year. No time restrictions are placed on compensated outside professional activity when the individual is on vacation leave.