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Review Process for Sponsored Research and Human Subjects Research

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 (and those of the Investigator’s Family Member) that reasonably appear to be related to the Investigator’s responsibilities to the University, as defined by an individual’s department or job description:

  1. With regard to any publicly traded entity, a Significant Financial Interest exists if the value of any Compensation received by the Investigator from the entity in the twelve months preceding the disclosure and the value of any Equity Interest in the entity as of the date of disclosure, when aggregated, exceeds $5,000.
  1. With regard to any non-publicly traded entity, a Significant Financial Interest exists if the value of any Compensation received by the Investigator from the entity in the twelve months preceding the disclosure, when aggregated, exceeds $5,000, or when the individual holds any Equity Interest; or
  1. Any instance where an Investigator 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 Employee, 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 policy).

However, Significant Financial Interest does NOT include:

  1. Salary, travel reimbursements, or other non-royalty Compensation from the University if the Investigator is currently employed or otherwise appointed by the University; or

  2. 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. 1001(a);

    3. an academic teaching hospital;

    4. a medical center; or

    5. a research institute that is affiliated with an institution of higher education within the United States; or

  3. Income from investment vehicles, such as mutual funds and retirement accounts, as long as the Investigator does not directly control the investment decisions made in these vehicles.

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Last Updated: 4/6/21