Guidance

A financial conflict of interest exists when an individual’s personal financial interests external to the University have the potential to influence, or bias, one’s judgment in executing professional responsibilities to the University of Utah. A financial conflict of interest is NOT an admission of wrongdoing. Having an external Financial Relationship does not necessarily mean a conflict exists.

To protect the researcher, the research team, the University, the science, the public, and human participants enrolled in research projects.

• Anyone listed as an Investigator of Research.
• Anyone engaging in Educational or Scholarly Activities.
• Anyone engaging in a Business Transaction between the University and an outside Business Entity.
• Anyone with Intellectual Property.

All Financial Relationships external to the University that are reasonably related to your responsibilities at the University.

All Intellectual property.

A Financial Disclosure Form can be submitted through the University of Utah Business Relationship Reporting system.

To view a short 5 minute video demonstrating how to use the tool, follow this link: Video Demonstration of Business Relationship Reporting

The University complies with federal and state laws that may require public disclosure of information relating to identified conflicts of interest. This includes making certain information available on a publicly available web site. Within the University, decisions about the management of conflicts of interest are routinely provided to appropriate University offices and to other employees whose responsibilities to the University are directly affected by the conflict of interest

Note: The COI Office CANNOT add/remove personnel from an IRB application. Please contact the IRB Office to make these changes.

• PRIOR to engaging in Educational or Scholarly Activity, Research, any Business Transaction with, or on behalf of, the University including purchases, contracts, grants, licensing agreements, and lease agreement.
• At least 30 days after acquiring a new financial interest.
• Within 90 days prior to new OSP award or IRB application, within 12 months prior to a milestone or continuing IRB review.
• Update annually

• Early-stage research: In addition to the examples of compelling circumstances provided in the 2001 AAMC Report, experimentation to further develop an early stage discovery may similarly require the insights, knowledge, perseverance, laboratory resources, or special patient populations of the discoverer. The best interests of patients who could benefit from the discovery may justify further involvement of the discoverer as an investigator. If such circumstances are deemed compelling by the applicable conflicts of interest committee, the analysis should define the stages of the research and the specific activities for which there are compelling reasons for the conflicted discoverer/investigator’s involvement, and an approved management plan should be structured to restrict the investigator’s roles to those stages and activities. The management plan should include a clear discussion of the time line proposed for elimination of the conflicted investigator from research participation and the strategy to restrict the time of involvement of a conflicted investigator to a minimum. Approval and management of the conflict may differ between experiments designed to promote further development on the one hand and those designed to validate claims linked to the discovery on the other. Approval of such research when human subjects are involved should require particularly stringent analysis of the degree of risk to subjects and of the effectiveness of particular provisions of the conflict management plan to protect subjects and prevent the introduction of bias of the conflicted investigator.

• Low risk research: In considering the degree of risk to human subjects, as called for in the 2001 Report, an institution’s conflicts of interest committee may encounter human subjects studies in which careful assessment finds risk to human subjects to be sufficiently low, so that the disposition of any associated conflict by the committee may be similar or identical to the disposition that would be made by that institution in non-human subjects research.