Conflict of Interest

Examples of Ways to Manage, Reduce or Eliminate Conflicts of Interest

RESEARCH

  1. Public disclosure of conflicts of interest to journals to which publications about the research are submitted or in public presentations of the research:

    Example of management plan statement:
    I will disclose my relationship with (business entity) to all journals to which publications based on this research are sent, and in all public presentations of this research.

    How to do it:
    The following are examples of statements that may be made in letters to journal editors, in the acknowledgements sections of articles, in PowerPoint presentations, on posters, verbally, etc., as appropriate to the situation.

    1. Dr. X is a consultant for XYZ Corporation, which funded this research.
    2. Professor Y has a significant financial interest in ABC Corp., Inc. that provided the materials being tested in this research.
    3. Professor Z is a co-owner of 123 Inc. that licenses technology she invented that is used in this research.
  2. Evaluation of/disclosure to subordinates/students.

    Examples of management plan statements:

    1. Subordinates will not be evaluated based on their participation (or lack thereof) in activities related to (business entity).

      How to do it:

      • If subordinates (junior faculty, students, staff) will not be involved in the activities related to the business entity, state that clearly.
      • If subordinates are involved in activities related to the business entity, describe how you will avoid evaluating them based on their participation or lack thereof. E.g. if the business entity is funding the research and students are working on the project, describe exactly how they will be evaluated
    2. I will disclose any conflict of interest for this project to students working on it as part of their studies, to the other members of the student's thesis committee (if relevant) and to the chair of the department, or, in the case of a chair with a conflict of interest for the project, to the chair of the department's graduate committee. I will notify students that, if they have any concerns about their participation, based on my conflict of interest, they can discuss those concerns with either the department chair or the chair of the department's graduate committee.
    3. How to do it:

      Describe how you will notify students and others of your conflict. Following is a sample letter:

    Dear Students and Committee Members,

    I am writing to formally inform you about a conflict of interest that I have in regards to PROJECT NAME. As you may already know, I [DESCRIBE RELATIONSHIP TO COMPANY, e.g. “am part owner of XYZ Corp” or “receive compensation from ABC Corp for consulting” etc.] Since this company stands to profit from this work, and since I stand to profit from the company, I have a “conflict of interest”, which has been officially disclosed to the University.

    As part of my disclosure to the University, I am informing you about this conflict. I encourage the members of your committee to ensure that I handle this conflict with appropriate professionalism. If you have any other concerns, please feel free to discuss them with me, any other member of your committee, the department chair, or the chair of the DEPARTMENT NAME graduate committee.

  3. Blinding of data or analyst(s)

    Examples of management plan statements:

    The person who analyses the data/samples will be blinded to the assignment of the data/samples to case or control group. Analysis will be conducted by a non-conflicted member of the research team who does not have access to the assignment information.

    How to do it:

    Describe which member of the team will do the analysis and confirm that s/he has no conflict of interest for this project.

  4. Modification of the research plan (where human subjects are involved):

    EXAMPLE OF A MANAGEMENT PLAN STATEMENT

    The conflict will be disclosed to all potential research participants in the consent process and consent documents.

    How to do it (language for consent documents):

    The [ROLE, such as PI, coordinator, nurse, etc.] for this project has a significant financial interest in(NAME OF COMPANY) the (TYPE OF COMPANY, such as the sponsor, lab, test supplier, etc) as determined by the University of Utah conflict of interest policy.

    Examples:

    1. The coordinator for this project has a significant financial interest in the sponsor, as determined by the University of Utah Conflict of Interest policy.
    2. The co-investigator for this project has a significant financial interest in the company that is providing the educational materials, as determined by the University of Utah Conflict of Interest policy.
  5. Monitoring of research by independent reviewers:

    EXAMPLES OF MANAGEMENT PLAN STATEMENTS:

    1. Dr. X, who does not have a conflict of interest for this project, will advise and consent on all major research decisions.
    2. b. Dr. Y, who does not have a conflict of interest for this project, will review the research and results every (interval).

    How to do it:

    Describe Dr. X or Y's credentials and why he/she is appropriate as a monitor of your research. Describe what Dr. X or Y will review and how often. Provide written confirmation that the suggested monitor agrees to take on this role.

  6. Conduct of all or part of the research by another, non-conflicted member of the research team or by a third party:

    Examples of management plan statements:

    1. Consent of research subjects will be conducted by (name, position), a non-conflicted member of the research team.
    2. Surgery on the animals will be contracted to the Animal Resource Center.

    How to do it:

    Identify the non-conflicted person/entity taking over the research function, and provide documentation that they will take it on.

  7. Divestiture of financial interests that present conflicts of interest:

    EXAMPLES OF MANAGEMENT PLAN STATEMENTS:

    1. I will sell my shares (or reduce my shares to below $10,000) in (business entity) prior to the start of the project.
    2. I will reduce my consulting for (business entity) to less than $10,000/year for the duration of this project.

    How to do it:

    Confirm the action with the Conflict of Interest committee.

  8. Severance of relationships that present conflicts of interest:

    Examples of management plan statements:

    1. I will resign my position as officer/director/agent/employee of (business entity).
    2. I will not consult for (business entity) until this project is completed.

PROCUREMENT

You may use the form “Purchasing Conflict of Interest Management Statement”. If no modification is made to this form, it will be accepted and approved as submitted. If, however, that form is not suitable to your situation, following are two examples of ways to manage, reduce or eliminate conflicts of interest related to purchasing/procurement.

  1. Monitoring of procurement:
  2. EXAMPLE:

    If a conflict of interest is determined to exist, any procurement transaction, including preparation of specifications, evaluation of bids or proposals, and the selection process leading to the award of a purchase contract, of any transaction between the University and (business entity) will be monitored by my department chair/college dean/supervisor (name, position). [This management plan requires confirmation by (name, position).]

  3. Removal from procurement process:
  4. EXAMPLE:

    If a conflict of interest is determined to exist, I will remove myself from the procurement process, including preparation of specifications, evaluation of bids or proposals, and the selection process leading to the award of a purchase contract, of any transaction between the University and (business entity).