"Standard" and "PI-Exclusion" Categories

CMPs are divided into two primary categories which vary depending on type and value of an investigator's outside financial interest:

  • "Standard" CMP, under which a conflicted investigator can remain as Principal Investigator (PI) with approval of a department chairperson and/or the COI Committee (COIC)
  • "PI-Exclusion" CMP, when certain outside financial interests do not permit an investigator to serve as PI, but allow service as a co-investigator

Standard vs. PI-Exclusion Comparison

View a guide outlining the types of financial interests that trigger a "Standard" or "PI-Exclusion" CMP.

Individual Conflict Management Plans (PDF) »

PI-Exclusion Rule

Under University Policy RI01 (formerly Policy 11-01-03), the following types of financial interests prevent an investigator from serving as Principal Investigator (PI), but he or she may serve as a co-investigator under a CMP:

Human Subject Research

  • Equity in and/or cash remuneration from a public company (in aggregate) greater than $20,000 per 12 month period or 5%*
  • Remuneration from a non-public company greater than $20,000 per 12 month period
  • Equity in a non-public company
  • Management or officer position in any company
  • Inventor or developer of intellectual property when receipt of royalties and/or other proceeds exceeds $10,000 per 12 month period
  • Reimbursed or sponsored travel from one entity exceeding $10,000 per 12 month period**

*5% restriction applies to non-PHS funded research only
**Only applicable to research funded in full or in part by a Public Health Service (PHS) agency

Animal and Bench Research

There is no automatic PI-Exclusion rule for animal and bench research. 

However, personnel holding a management or officer position in any University Licensed Start-up Company (LSC) must obtain prior written approval from the Senior Vice Chancellor for Research (upon recommendation from the COI Committee) to serve as PI of animal or bench research that is of commerical interest and/or sponsored by the LSC.  The COI Office can facilitate this process as part of an ancillary review.

Exception Requests

Exceptions to the PI-Exclusion rule must be approved by the authorized institutional official for human subject research, Professor George A. Huber, Vice Chancellor for Research Protections.  The only justification that will be considered for such an exception is for the protection of human subjects.

All other exceptions or changes to required CMP elements under the "Standard" and "PI-Exclusion" categories must be approved by a subcommittee of the COI Committee. 

All exception requests may be communicated directly to the COI Office via email for further review and consideration.  Please note all exception requests take several weeks to review and may require deliberation by the full COI Committee at one of its regularly scheduled monthly meetings.

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