Conflict of Interest and Conflict of Commitment Assessment
The term "Conflict of Interest" refers to situations where the individual has the opportunity to influence UT Health San Antonio’s business, administrative, academic, research, clinical, or other decisions in ways that could lead to personal financial gain or advantage or could appear to cause bias in the design, conduct, or reporting of research or educational activities.
The term "Conflict of Commitment" refers to situations where the individual undertakes external commitments that burden, interfere with, or detract from the member’s primary obligations and commitments to UT Health San Antonio.
iDisclose is the UT Health San Antonio Conflict of Interest and Conflict of Commitment reporting system.
Use this site to disclose any interactions with external entities that may be related to your job at UT Health.
iDisclose is the online system used by Faculty and Exempt Staff to report external (or outside) activities. Each reported activity is referred to?as a “disclosure”. iDisclose provides a single portal to capture information used to fulfill several administrative and reporting needs such as:
Faculty and staff engagement in outside activities may be subject to one or more federal, state or local rules and regulations. The HSC is required by UT System to collect and report information regarding the HSC staff’s outside employment and activities. The HSC requires staff to report all outside activities through iDisclose. The following are a few examples of the complexity of these rules:
|You...||Prior Approval||Conflict of Interest||Conflict of Commitment||UT System Annual Report|
|are compensated for reviewing grant proposals submitted to the NIH.|
|own equity in a company related to the work you do at the HSC. You are not paid by the company.|
|are a paid consultant for a company that is also sponsoring a research study where you are the PI.|
|are an unpaid member of the Board of Directors of a non-profit professional organization. You use work time to fulfill your membership responsibilities.|
|own $25K worth of stock in a major pharmaceutical company. You have no consulting, research or other relationships with the company.|
|receive royalties from the HSC but do not have any relationship with the licensing organization.|
Each disclosure is reviewed by the VPR’s Conflict of Interest Manager who determines whether any of the policies apply. Depending on the type of activity, your disclosure will be routed to the appropriate reviewers and/or Conflict of Interest Committee.
This Quick Reference .PDF provides a different visualization of the process.
With exceptions, all external activities and financial interests including compensated activities, equity interests related to your Health Science Center responsibilities, reimbursed or sponsored travel, un-compensated activities relating to your Health Science Center responsibilities, intellectual property and royalty income, gifts exceeding $250 in value, fiduciary positions and other business or financial interests in legal entities.
|Fiduciary Role||Serving as Chief Executive Officer, Chief Scientific Officer, an elected officer, or member of the Board of Trustees, Governing Board or Board of Directors.|
|Advisory Board Member||Serving as a member of an advisory committee including scientific advisory boards, data safety monitoring boards, or steering committees for a clinical trial.|
|Speaker, Trainer, Educator||Compensation from any non-UTHSC entity for a speaking engagement, including honoraria, stipends or fees to train/educate.|
|Consultant||Professional services to a non-UTHSC entity other than those defined above.|
|Inventor, Designer or Founder Rights||Compensation received in the form of rights to royalties, license fees, or some form of ownership, for exapmply equity, such as stock, stock options, or a future distribution of UTHSC interests.|
Both are considered disclosures and will appear in your annual disclosure report. As the name implies, activities such as:
Once your disclosure is submitted through the iDisclose system, it will be screened by the Conflict of Interest Manager and then sent for review to your Supervisor, Department Chair or Dean (or equivalent positions for non-faculty).
When interactions are reported that have the appearance of a conflict of interest, the HSC Conflict of Interest Committee will provide additional review and make a determination as to whether a real or potential conflict exists.
The committee is comprised primarily of HSC faculty although there is also representation from the HSC administration and the community. It reviews and considers information provided to them regarding any potential conflict of interest. If the committee determines a conflict exists, a management plan will be developed with your input to reduce or eliminate any real or perceived conflict. It is important to understand that sometimes even the appearance of an inappropriate conflict may be cause for concern.
The management plan is further reviewed by the Institutional Review Board (if the conflict involves human subject research), the applicable Dean and the Vice President for Research.
In publicly disclosing this information, UTHSC tries to provide information as accurately as possible about its faculty and staff member’s connections with business entities and those of their immediate family members. The information presented on this web site may differ somewhat from information in other publicly available databases. Some discrepancies may arise from different reporting periods, different definitions or different reporting requirements. Patients should feel free to contact their doctor about relationships with business entities, such as pharmaceutical and device companies, and how these relationships are overseen by the HSC. Inquiries about this web site or how HSC manages collaborations with business entities can be made via the Contact information on this page.
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A “Significant Financial Interest” is anything of monetary value and includes, but is not limited to:
The definition applies when:
Annual reporting and updates when required satisfies the requirements of various Health Science Center, UT System, State of Texas, and federal policies regarding reporting (disclosing) external activities and interests and allows the Health Science Center to determine whether the individual’s activities and interests are consistent with policy requirements and to take actions, if necessary, to manage real, potential, or perceived conflicts of interest or commitments.
Family is any spouse, dependent child, stepchild or any other person financially dependent on the individual making the report, and any other person with whom the reporting individual has joint financial interests such that an objective third party could reasonably conclude that the reporting individual’s decisions or other exercise of professional responsibilities at the Health Science Center could be influenced by the effect of that action on the person’s financial interest. Any individual may be identified as family without regard to whether a legal or biological relationships exists with the HSC Faculty or Staff member.
Yes. The Annual Report requires not only information regarding Significant Financial Interests, but also requires information concerning any external compensated or un-compensated professional activities or interests as well as an individual’s service on no-profit boards and receipt of gifts.
If you have nothing to disclose the report takes seconds to complete and acts as an annual confirmation of your status.
Yes. The Annual Report establishes the fact that your activities do not meet the definition of "Significant Financial Interest". It also captures information concerning any un-compensated professional activities or interests as well as activities such as service on no-profit boards and receipt of gifts.
Compensation includes personal income, honoraria and consulting service fees that are received from sources outside the Health Science Center. Compensation differs from employment in that it is short term or episodic in nature.
The aggregate of all compensated outside professional activities may not exceed 30% annually of your Health Science Center institutional base salary (assuming the individual is full-time at the Health Science Center). Classified staff should reach agreement with their Department Chair or Director.
A full-time faculty member may engage in compensated and un-compensated outside professional activities no more than a cumulative average of four days per month during the calendar year; these days may not be carried forward from year to year. No time restrictions are placed on compensated outside professional activity when the faculty member is on vacation leave. However, an individual college or other unit may have more restrictive guidelines.
Classified staff are required to take vacation time in most instances when they are compensated for their outside activities.