The ICOIC reviews certain transactions between the University and external entities known as “Threshold University Transactions”. The ICOIC determines whether the proposed transaction creates an ICOI and, if so, recommends a Conflict Management Plan (CMP) as advice to the relevant Senior Decision Makers for approval.
Transactions subject to ICOIC review include:
- Gifts to the University with an aggregate value >$500,000 in a 12-month period made by a commercial entity or by a philanthropic unit affiliated with a commercial entity.
- When University-owned technology is licensed or optioned to an external entity and the technology will be tested or evaluated at the University and the research will include (1) human subjects, (2) cells derived from or mimicking human cells, (3) tissues obtained from human subjects or (4) using other methodologies defined by the ICOIC.
- When the University holds equity in the proposed sponsor of University research, scholarly activities or teaching.
- For privately-held entities, when the University holds any equity interest in the entity
- For publicly traded entities, when the University holds equity in the entity valued at >$100,000
- When a CUO has a Significant External Activity in an entity and
- The entity proposes to sponsor University research, scholarly activities or teaching
- University purchases from the company exceed $100,000 in a 12-month period; or
- The entity licenses or proposes to license University data or biological samples
The ICOIC may review potential ICOIs that are not listed above when they are referred by other University committees, such as the Conflict of Interest Committee, Institutional Review Board (IRB), or the University Senate.