What is a Conflict of Interest?
The term “Conflict of Interest” refers to situations where the individual has the opportunity to influence the Health Science Center’s business, administrative, academic, research, clinical, or other decisions in ways that could lead to personal financial gain or advantage or could cause to appear to cause bias in the design, conduct, or reporting of research or educational activities.
What is a Conflict of Commitment?
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 the Health Science Center.
What is a Significant Financial Interest?
A “Significant Financial Interest” is anything of monetary value and includes, but is not limited to: salary or other payments for services (e.g., consulting fees or honoraria): equity interests (e.g., stocks, stock options or other ownership interests); and intellectual property rights (e.g., patents, copyrights, and royalties from such rights.) This includes:
What is the purpose of the annual disclosures of external activities (conflicts of interest reporting) and any subsequent updates?
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.
Who is required to file an annual disclosure?
Who is considered Family for reporting purposes?
For reporting purposes, family is any spouse, dependent child or stepchild, 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 reporting individual.
What must be reported and when?
The individual is expected to report all of their outside activities as well as those equity holdings which relate to their Health Science Center responsibilities. Reporting is completed on an annual basis through an electronic system system and should be updated if significant changes occur prior to the next annual reporting period.
What is the difference between the annual reporting of financial interests (conflict of interest annual report) and the IRB Form X?
The COI Annual Report and any updates covers all of the reporting individual’s external activities and interests. The IRB Form X, completed at the time of IRB protocol submission, covers only the individual’s external activities and interests relating to the specific protocol regardless of the amount of compensation or interests in the external sponsor; in other words, Form X requires information that is relevant to one activity; the COI Annual Report covers everything.
Do I have to complete the report even if I have no activities to disclose or if my interests are less than amounts as defined in “significant financial interest?
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 or receipt of gifts.
For reporting purposes, what is compensation? For example, does it include reimbursement for travel expenses for consultations/advisory board meetings?
Compensation includes personal income, honoraria, travel expense reimbursement and consulting service fees that are received from sources outside the Health Science Center.
Is there a dollar limit that I can receive annually in honoraria and consulting fees?
The aggregate of all compensated outside professional activities may not exceed 30% annually of the individual’s 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.
Is there a time limitation on outside activities?
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 where they are compensated for their outside activities.