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Conflict of Interest (COI)

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Individual Financial Conflict of Interest Policy

The Individual Financial Conflict of Interest Policy 1-006 applies to all University employees and investigators who participate in research with the University. It prescribes procedures for disclosure of financial interests by the individual employee, review conducted by the Individual Conflict of Interest Committee, and for the exercise of ongoing oversight and management where necessary. It indicates the sanctions that may be applied when the policy is violated. The policy is based on federal financial regulations promulgated by the Department of Health and Human Service (DHHS) and other federal agencies, and is compliant with all NIH, DOE, NSF, FDA, and other federal requirements.

As appropriate, subcontractors and other external research collaborators must also comply with this policy unless their institution/company provides adequate assurances that they are compliant with the federal regulations referenced above. This policy applies to any research, education or service activity regardless of whether or not support is provided to the University or employee. Support may be in the form of sponsorship, incentive, equipment or gift.
 
Many other University of Utah, state, and federal policies are also applicable in the governance of conflicts of interest.

* This policy overlaps with but does not supplant University Employees' responsibilities under the Utah Public Officers' and Employees' Ethics Act, Utah Code Annotated § 67-16-1 et seq. (the Ethics Act), which in some instances may include additional reporting responsibilities. In many instances, this policy is broader than the Ethics Act in the situations covered. Also, incorporated by reference are the National Science Foundation Policy; Department of Health and Human Services, Responsibility of Applicants for Promoting Objectivity in Research for Which Public Health Service Funding Is Sought and Responsible Prospective Contractors [Fed Regist. 2011 Aug 25;76(165):53256-93]; 42 CFR Part 50, Subpart F and 21 CFR Part 54; Food and Drug Administration, Financial Disclosure by Clinical Investigators. As additional external federal policies are imposed, this policy will incorporate such new policies by reference.

Conflicts of Interest Related to Research

Conflicts of Commitment and Use of University Resources

Conflicts of Interest Related to Business Transactions

State Law Regarding Conflicts of Interest

Conflicts in the Workplace

Federal Policies

Last Updated: 1/4/24