Review Process

When evaluating Research for conflicts of interest, the Conflict of Interest Office, on behalf of the Individual Conflict of Interest Committee, will determine, for each Investigator’s Disclosure Form, whether the Investigator has a Significant Financial Interest (defined below), which requires the review of the Conflict of Interest Committee. The individual Investigator’s department chair or supervisor will be notified when the Conflict of Interest Office refers a potential conflict of interest to the Conflict of Interest Committee for review.

"Significant Financial Interest" means a financial interest consisting of one or more of the following interests of the individual Investigator (or those of the Investigator's Family Member) that for a University Employee, reasonably appear to be related to the Investigator's responsibilities to the University, as defined by their department or job description, or for an Investigator who is not a University Employee, reasonably appear to be related to their employer or profession:

1. With regard to any publicly traded Business Entity, a Significant Financial Interest exists if the value of any Compensation received by the individual from the Business Entity in the 12 months preceding the disclosure and the value of any Equity Interest in the Business Entity as of the date of disclosure, when aggregated, exceeds $5,000.
2. With regard to any non-publicly traded Business Entity, a Significant Financial Interest exists if the value of any Compensation received by the individual from the Business Entity in the 12 months preceding the disclosure, when aggregated, exceeds $5,000, or when the individual holds any Equity Interest; or
3. Any instance where an Investigator (or a Family Member) has, or reasonably foresees having, the right to receive Compensation as a result of licensing or other commercialization of Intellectual Property created by that Investigator (or Family Member), including the right to receive shares of revenue, royalties, or other payments generated by such commercialization (e.g., an inventor’s share of royalty income under University regulations).
4. In Research sponsored by the United States Department of Energy and other agencies that have adopted a similar requirement, Significant Financial Interest includes:
  1. any reimbursed or sponsored travel (i.e., that which is paid on behalf of an Investigator and not reimbursed to the Investigator so that the exact monetary value may not be readily available) related to an Investigator’s institutional responsibilities; and
  2. other external support exceeding a valuation of $5,000 (i.e., all resources made available to an Investigator in support of and/or related to all of their professional research (including basic and fundamental research), development, demonstration, and/or deployment efforts, including resources provided directly to the Investigator rather than through the research organization, and regardless of whether or not they have monetary value (e.g., even if the support received is only in-kind, such as office/laboratory space, equipment, supplies, or employees). This includes resource and/or financial support from all foreign and domestic entities, including, but not limited to, gifts provided with terms or conditions, gifts provided without terms or conditions, financial support for laboratory personnel, and participation of student and visiting researchers and visiting scholars supported by other sources of funding.

However, “Significant Financial Interest” does not include:

Salary, travel reimbursements, or other non-royalty Compensation received by the Investigator (or a Family Member) from the University if the Investigator (or a Family Member) is currently employed or otherwise appointed by the University;
Unless required to be considered a Significant Financial Interest by the Research sponsor, income received by the Investigator (or a Family Member) from seminars, lectures, or teaching engagements sponsored by, or income received by the Investigator (or Family Member) from service on advisory committees or review panels for the following entities within the United States:
1. a federal, state, or local government agency;
2. an institution of higher education as defined at 20 U.S.C. Sec.1001(a);
3. a research institute that is affiliated with an institution of higher education within the United States;
4. for Research other than Research funded by the United State Department of Energy:
  1. an academic teaching hospital; or
  2. a medical center; and
5. any other entity excluded by the federal sponsor.
Income received by the Investigator (or Family Member) from investment vehicles, such as mutual funds and retirement accounts, provided that the Investigator (or Family Member) does not directly control the investment decisions made in these vehicles.