Identification
The COI Division identifies potential institutional conflicts of interest (ICOIs) by reviewing:
- Outside activities, interests, and relationships disclosed by Covered University Officials (CUOs) in MyDisclosures
- Proposals, awards, contracts, or agreements referred by the Office of Sponsored Programs
- Human subjects research study when the PI or a study team member indicates the University has a financial interest in the IRB protocol
- Gifts referred by Philanthropic & Alumni Engagement
- Purchases referred by Purchasing Services
Review and Management
When a potential ICOI is identified, ICOI Committee review is required.
If an ICOI requiring management is identified, the ICOI Committee recommends a CMP, the terms of which depend on whether the University or a CUO is conflicted, the type and level of the financial interests or significant external activities, and the nature of any related research. The CMP is shared as advice with the Senior Decision Makers and, when relevant, supervisors of conflicted CUOs for approval.
Execution of the CMP
Relevant individuals will be required to sign the CMP via DocuSign, including the conflicted CUO and the Principal Investigator of any University research in which the University or CUO has related financial interests. The COI Division will provide a copy of the signed CMP to the Senior Decision Makers and any other relevant individuals.
Animal or Human Related Research
When the CMP applies to animal or human research, the COI Division will upload a copy of the signed CMP to the relevant IACUC or IRB protocol and will communicate to the IACUC or IRB if the study team must submit a protocol modification to indicate the University’s financial interest in the research, a CUO’s financial interest in the research or, for human research, to include financial interest disclosure language in consent forms or scripts.