Conflict of Interest (COI) FAQs

• How are Research-Related COIs and Conflict of Commitment (COC) related?

  While COI and COC may both relate with an Investigator’s financial interest and their institutional responsibilities, this campus has separate offices, policies, and procedures for dealing with each.

  Research-Related Conflicts of Interest: Situations where an investigator's outside financial interests (e.g., salaries; consulting income; receipt of income from intellectual property rights; equity interests; ownership of equity in publicly or privately held businesses; honoraria; gifts; loans; or travel payments) or paid or unpaid obligations (e.g., director, officer, partner, consultant or manager of an entity) bias or have the potential to bias a research project. This also applies to the immediate family members of that investigator. For more information, Investigators should contact COI. Conflicts of Commitment: The UC Regents’ Standing Order 103.1(b) states that faculty members shall not allow outside employment to interfere with primary University duties. University policy applicable to Academic Senate members is found in APM-025 (general campus faculty) and APM-671 (Health Science Compensation Plan Faculty); each policy includes specific time limits for certain types of outside professional activities. Whether professional or non-professional, compensated or uncompensated, an outside activity that interferes with successful performance of a faculty member’s University obligations represents a conflict of commitment. To comply with APM policy, UCR faculty must: 1) obtain Prior Approval and 2) submit an Annual Report.

  For more information on COC, see this page provided by the Office of Academic Personnel.

• What are some examples of mitigation or management plans to address COIs?

  Some examples of how to manage, eliminate, or reduce potential research related conflicts of interest:

  • Public disclosure of significant financial interests.
  • Training on research-related conflicts of interest for all personnel involved in the research.
  • Monitoring of research by independent reviewers.
  • Double-blind study and/or randomized study
  • Modification of the research plan to ensure objectivity.
  • Have non-conflicted investigators collect data and perform data analyses.
  • Remove oneself as the Principal Investigator.
  • Disqualification from participation in all or a portion of the research.
  • Divestiture of significant financial interests.
  • Severance of relationships that create actual or potential conflicts.
• I have a positive disclosure related to my research project that will be sent to COI for review. When will I receive the results of the review, so my study funds may be released?

  Depending on the nature of the disclosure the review may take four to six weeks to be reviewed by the ORC and COI Committee. ORC staff will contact you if additional review is required.

• When not reporting COIs, what are some of the potential risks?

  If you have any concerns regarding COI issues, we strongly encourage you to contact our office immediately. There are significant risks involved for not reporting:

  • Compromise of scientific integrity (objectivity of the research);
  • Misuse of University facilities;
  • Improper direction of student’s or University employee’s work;
  • Unbalanced allocation of faculty member’s time and effort;
  • Failure to recognize the University’s right to intellectual property and related financial interests;
  • Improper channeling of research funds;
  • Inappropriate delay or restriction on publications;
  • Appearance of impropriety

Founding or Advising to a Company

• What are some general principles to keep in mind when starting a company?
  • Having a non-conflicted investigator and blinding the study will help mitigate the conflict; however, COI will still need to review all the factors to determine if the mentioned management is necessary and/or sufficient. 
  • Keep your company activities separate and distinct from UC research and administrative activities.
  • Expect your company to be treated exactly like any other company.
  • File a disclosure to evaluate potential conflicts and mitigate risk, if necessary.
  • Not all research-related conflicts are impermissible, and most are manageable.
  • When human subjects are involved, there will be a higher level of examination.
  • Case-by-case analysis and management is crucial.
  • When in doubt, disclose to COI.
• Can I start a company?

  UCR's research-related conflict of interest and conflict of commitment policies do not prohibit investigators from starting their own company, however there may be conflict of interest disclosure requirements and approvals required. Please contact COI for more information. For additional information on start-ups and entrepreneurial activities at UCR, visit the Entrepreneurial Proof of Concept and Innovation Center (EPIC) website.

• Can I serve on a board of directors?

  UCR's research-related conflict of interest policy does not prohibit investigators from serving on a Board of Directors, Advisors, or similar. If this position also involves other financial interests such as income or equity interests, the investigator may have additional COI disclosure requirements. Should the COI Committee determine that these interests could potentially be a conflict of interest in conjunction with the research, the Committee will require the investigator to take steps to manage, reduce, or eliminate the conflict before the research can proceed. Investigators who are contemplating serving on a board should contact COI as soon as possible to discuss conflict of interest issues related to their research. 

  Service on a Board of Directors carries with it legal fiduciary responsibility, but not management responsibility therefore, this position is permissible. The investigator’s primary commitment is to the University and service on a Board of Directors should not interfere with his/her primary obligations as a faculty member or university employee. For more information on COC, see the Conflict of Commitment and Outside Professional Activities website.

• Can I serve on a scientific advisory board?

  Serving on a Scientific Advisory Board is permitted because such positions do not carry, nor are they perceived to carry, management responsibility. The investigator, however, should recuse himself/herself from any discussion or decision to fund his/her own research. If this position also involves other financial interests such as income or equity interests, the investigator may have additional COI disclosure requirements.

• I serve as consultant to a company and want to test a product from that company. What are ways to mitigate the conflict?
  • Having a non-conflicted investigator and blinding the study will help mitigate the conflict; however, COI will still need to review all the factors to determine if the mentioned management is necessary and/or sufficient.
  • Some factors that the COI will review includes but is not limited to:
  • Understanding who has supervisory authority of all research personnel involved in the study.
  • Determining if there are any research personnel under the supervision of the conflicted individual.
  • Knowing if there is a non-conflicted investigator that reports to the conflicted individual.
  • Verifying if students are involved and if so, who is supervising them.
  • Identifying who is doing the data analysis, collection, and reporting.
  • Recognizing if there are Human Participants involved.
  • COI may require additional measures to protect the objectivity of the research, depending on the level of risk created from the financial interest and how the study is designed.
• I am a co-founder in a company that would like to provide funds to my lab at UCR through an industry-sponsored research agreement. Am I allowed to do this? If so, what should I be concerned about?

  One concern is the need to be ensured that you do not represent both the University and the company in the industry-sponsored research negotiations or any business transactions. For example, recommendations include that 1) your company hire a lawyer to represent the company in business transactions with the University, or 2) your company include a company representative that doe not have a University affiliation. This example could be considered a potential research-related conflict of interest if you have a financial interest in the company and are an investigator on the award. If you, the Principal Investigator or Co-Principal Investigator of the study, have financial interests in the company, you will need to disclose this financial interest.

• I am a consultant to a company that would like to provide funds to my lab at UCR through an industry-sponsored research agreement, am I allowed to do that? What should I be concerned about?

  Companies may provide funds to your lab but that could potentially trigger a COI review. If you have a financial interest in the sponsor and you are the Principal Investigator (or Co-Principal Investigator), your disclosures may need to be reviewed and approved by COI.

Intellectual Property and Technology

• Can I participate in research sponsored by a company that licensed technology I invented at UCR?

  Your participation in the research could be considered a potential research-related conflict of interest if you have a financial interest in the sponsor. If you have financial interests in the sponsor, you may need to disclose your financial interest.

  For a detailed summary of the thresholds, please see the State Law column in the UCR COI Disclosure Chart.

• Through the university, I am an inventor on a patent. May I serve as an investigator testing its effectiveness?

  This is possible but it depends on the sponsor of the research. It also depends on whether you have a financial interest in the sponsor or one related to the research project, and how the financial interest is managed.

  If you have a financial interest in the sponsor or one related to the research, your situation may need to be reviewed by COI.

Equity

• May I own stock in a publicly traded company and serve as an investigator on a study for that company’s products?

  You could serve as the investigator on a study, however depending on who the sponsor of the study is and the percentage and/or the value of the stock, you may be required to disclose and go through a COI review. For a more detailed summary of the thresholds, please see the UCR COI Disclosure Chart.

• I have equity in a company that would like to provide funds to my lab at UCR through an industry sponsored research agreement, am I allowed to do that? What should I be concerned about?

  This is allowable for you to own stock or have equity in the company that would like to provide funds to your lab. However, if you do have a financial interest in the company and you are an investigator, your disclosures may need to be reviewed and approved by COI if it meets the sponsors thresholds.