POLICIES: CONFLICT OF INTEREST
“The public trust in what we do is just essential and we cannot afford to take any chances with the integrity of the research process.” Dr. Francis Collins, Director, National Institutes of Health
Research objectivity is crucial and is the basis for obtaining and maintaining public trust. The United States Government developed regulations designed to promote objectivity in research by establishing standards which provide a reasonable expectation that the design, conduct and reporting of federally funded research will be free from bias resulting from investigator financial conflicts of interest (42 CFR Part 50 Subpart F).
State employeees interested in pursuing outside employment should refer to the Code of Ethics for further information. Minnesota State Colleges and Universities Office of General Counsel website gives specific information related to State Employee Ethical Obligations.
Investigators are required to disclose to the institution such interests before or when applying for external research funding. To assist in this process, we've developed the following materials to provide guidance in the process of identification and disclosure:
- Conflict of Interest Brochure
- Conflict of Interest Disclosure Form
- Travel Disclosure Form
Financial conflict of interest training will be conducted through the Collaborative Institutional Training Initiative (CITI) required and elective courses. Investigators identifying a conflict of interest on an externally funded grant or contract or all new or existing investigators of PHS-funded research will be required to complete conflict of interest training prior to engaging in the research and every four years thereafter. Training is also required when the institution finds an investigator not in compliance with the institution’s financial conflict of interest policy or management plan. Training available at: https://www.citiprogram.org/.
- Conflict of interest exists when personal, professional, financial or other private interests of a person or institution compromise, have the potential to compromise or may be perceived to compromise the exercise of professional judgment or obligations.
- Financial conflict of interest is any financial interest or a significant financial interest which could directly and significantly affect the design, conduct or reporting of externally funded research.
- Investigator could be the project director, principal investigator or any other person, regardless of title or position, who is responsible for the design, conduct or reporting of research funded or proposed for funding. This includes collaborators, consultants, post-doctoral fellows, graduate students, etc.
- Investigator institutional responsibilities may include activities such as research, research consultation, teaching, professional practice, institutional committee membership, serving on panels, etc. performed on behalf of the institution.
- Public Health Service agencies include the National Institutes of Health (NIH), Food and Drug Administration (FDA), Centers for Disease Control and Prevention (CDC), Indian Health Service (IHS), Health Resources and Services Administration (HRSA), Substance Abuse and Mental Health Services Administration (SAMHSA), Agency for Healthcare Research and Quality (AHRQ), Centers for Medicare and Medicaid Services (CMS), Administration for Children and Families (ACF), or Administration on Aging (AOA).
- Significant financial interest has a monetary value, whether or not the value is readily ascertainable, to the investigator or his/her spouse, domestic partner or dependent child(ren) related to the investigator’s institutional responsibilities.