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Frequently Asked Questions

The responses to the following responses are based on the revised Individual Financial Conflict of Interest Policy that will be effective August 24, 2012.

If you have a question that is not answered here, please submit your question in an email to coi@hsc.utah.edu.  We will be posting responses to new questions regularly.

A conflict of interest is a situation in which the potential exists for an individual’s personal financial interests to impair his/her judgment in the execution of his/her responsibilities to the University of Utah.

If you are not affiliated with the School of Medicine, you need to report all Significant Financial Interests for you and your Family Members (spouse/domestic partner and/or minor/dependent children) that reasonably appear related to your professional responsibilities to the University, as defined by your department or job description.

If you are affiliated with the School of Medicine, the Industry Relations Policy requires that you disclose ALL external business relationships, which includes:

For you or your Family Member

  • Any equity ownership interests (e.g. stock, partnership interest, member interest) in an industry business entity, excluding ownership in mutual funds and/or pension funds.
  • Any leadership position (e.g. officer, director, partner) in an industry business entity.
  • Any intellectual property ownership in the products of an industry business entity.

For a publicly traded company, a Significant Financial Interest exists when the combined value of any remuneration AND the value of any Equity Interest(s) as determined through reference to public prices or other reasonable measures of fair market value, when aggregated for you and your Family Members, exceeds $5,000 during twelve months. 

For a non-publicly traded company, a Significant Financial Interest exists when the combined value of remuneration, when aggregated for you and your Family Members, exceeds $5,000 during twelve months OR when you or your Family Members hold an Equity Interest of any value. 

Remuneration includes salary and any other payments not otherwise identified as salary (e.g., gifts, consulting fees, honoraria, paid authorship).  The following sources of income are excluded from the definition of "Remuneration" and do not need to be disclosed:

  • Income from seminars, lectures, teaching engagements, advisory committees or review panels sponsored by a federal, state, or local government agency, an institution of higher education, an academic teaching hospital, a medical center, or a research institute that is affiliated with an institution of higher education.
  • Income from investment vehicles, such as mutual funds and retirement accounts, as long as you and your family members do not directly control the investment decisions made in these vehicles.
  • Salary, travel reimbursements or other non-royalty remuneration from the University of Utah if you are currently employed or otherwise appointed by the University.
 An Equity Interest is any stock, stock option, or other ownership interest in a business entity. 
Yes, the definition of Significant Financial Interest also includes intellectual property rights and interests (e.g., patents, copyrights), when the patent application is filed or when the copyright is asserted or upon receipt of income related to such rights and interests, including royalty income from Intellectual Property owned by the University of Utah Research Foundation.
Within the University, the information provided in your disclosure is confidential and is only used for the purposes of administering the policy by the Conflict of Interest Committee and other University offices with oversight responsibilities, as appropriate.
Under certain circumstances, the University is required to make personal financial information publicly available to comply with federal and state law.
No, many significant financial interests do not create a conflict of interest. You are required to disclose all significant financial interests that reasonably appear related to your professional responsibilities to the University, as defined by your department or job description. The University is responsible for determining whether the significant financial interest creates a conflict of interest. 
The University utilizes a peer review process to determine if a conflict of interest exists. The Individual Conflict of Interest Committee, as designated in Policy 1-006, includes faculty and staff who are charged with reviewing significant financial interests to identify conflicts of interest that need to be managed, reduced or eliminated.
The Individual Conflict of Interest Committee will work with you to design a way to manage, reduce or eliminate the conflict (a “management plan”).  For activities other than human subjects research, the Committee tries to design a management plan that will allow you to continue your University work while ensuring that your personal financial interests do not negatively affect that work. If the Committee determines that management is not possible for your circumstances, you may be required to eliminate your conflict of interest by divesting your financial interest or changing some aspects of the work you do for the University.
Yes, research involving human subjects must receive the highest level of protection from bias or appearance of bias created by an individual’s conflict of interest. The Committee is required to apply a “rebuttable presumption” standard, which is a presumption against the conduct of research with human subjects in any circumstance where the individual has a conflict of interest relating to the research. The Committee may approve conduct of the research by the individual only upon a finding of compelling circumstances and only when the Committee can craft an effective management plan to mitigate the conflict. Otherwise, the conflict must be eliminated or the research project shall not be conducted by the individual. 

The Individual Conflict of Interest Committee routinely makes the Committee’s determinations and management plans available to:

  • the individual’s University superiors (Department Chair/supervisor)
  • the appropriate University offices, including but not limited to, the Office of the Vice President for Research, the Office of General Counsel, Internal Audit, Institutional Review Board, Office of Sponsored Projects, Technology Commercialization Office, Procurement and Supply Management, Graduate School
  • other Employees whose responsibilities to the University are directly affected by the conflict of interest

Depending on the specific circumstances, the management plan approved by the Committee may also require disclosure of the conflict to human subjects participating in research, to students or other subordinates at the University, and/or disclosure of the details about your financial relationships on the University’s publicly available Conflict of Interest web-site.

 A short program entitled “Conflicts of Interest in University Academic Research” is available for presentation at faculty meetings and department forums. The Research Administration Training Series (www.education.research.utah.edu ) offers several classes and programs designed to ensure compliance with national and local regulations. You may also contact the member of the Conflict of Interest Committee most closely associated with your college or department at any time to discuss policies in greater detail. For more information please contact Tony Onofrietti, Director of Research Education, at 585-3492 or tony.onofrietti@hsc.utah.edu.
Last Updated: 8/29/17