Conflict of Interest in Research
The Office of Research Integrity and Compliance (ORIC) is here to help you identify, report, and manage Conflicts of Interest in Research.
COI in research may occur when an investigator's private interests (such as outside professional or financial relationships) compete with their ability to objectively design, conduct, or report research.
Research COIs are increasingly part conducting research and do not suggest any impropriety on the part of the research investigator. Most conflicts can be successfully resolved without impeding research activities. A COI may exist despite the investigator's adherence to the highest standards of conduct.
Having a COI does not prevent you from doing research at UNM, nor does it, in most cases, affect your ability to apply for and receive funding. What both UNM Faculty Handbook policy E110 and funders require, however, is that the COI be disclosed and managed. ORIC’s role is to help you do both.
The general rule is that anyone who can affect the objectivity of UNM research, either during the planning stage, supervising those who perform the actual work of research, and those who report results through authoring articles, reports, conference presentations, etc. Practically this means Principal Investigators (PI), Co-Investigators, and any named Key/Senior Personnel on the project. Postdoctoral students and senior graduate students may also fall into this category. The decision on others who might need to report is ultimately up to the PI on the project. Please note that this can include people external to UNM who do not have an affiliation which conducts its own federally compliant COI process. A question frequently arises regarding what is considered research at UNM. For COI purposes this includes:
- Sponsored Research, formally defined in UNM policy as “sponsored research, service, training projects, and other categories of awards for all except basic capital construction and maintenance projects.”
- All research involving human subjects.
- All research involving vertebrate animal subjects.
- Certain internally funded projects requiring a proposal process (e.g. RAC, SuRF).
In general, you should disclose any interest, financial or otherwise, outside of UNM that could affect your ability to conduct your research objectively and with the public interest in mind. Keep in mind that you are required to report these interests for yourself, your spouse/dependent partner, and dependent children (those you can claim on your tax returns). While this may seem intrusive, it is required by federal regulations. This ensures that you cannot be accused of using public funding or resources for your own benefit, rather than that of the public at large. The Federal government is becoming increasingly concerned with research funded by our tax dollars being used for the benefit of foreign governments, military operations, and corporations, to the detriment of US interests.
UNM requires reporting of both financial and non-financial COIs. Our policy is based on the most stringent requirements of funding agencies, for simplicity and optimal compliance.
Examples of financial COI that must be reported according to UNM policy are:
- Outside employment, including consulting, where earnings >$5000.
- Any consulting activity related to your research/university responsibilities.
- Any ownership, stock, or stock options in a domestic private for-profit company.
- >5% ownership or stock of stock options in any domestic publicly traded for profit company.
- Royalties for intellectual property (patents, copyrights, etc.) other than those that are through Rainforest Innovations.
- Stock or stock options in any-for profit companies >$5000 if the business of that company can be reasonably construed to be related to your research or can directly benefit from the results of your research.
- Stock or stock options in domestic any-for profit companies >$100,000.
- Any ownership, stock or stock options in any foreign company.
- Any venture capital received from any foreign source.
- Any travel sponsored by a commercial domestic entity or any foreign entity.
- Gifts through the UNM Foundation to support your research.
- Participation in Foreign Talents Programs in which you receive salary or other financial compensation.
These examples are the most common situations and are not intended to be exhaustive. If you have questions regarding what you need to disclosure, please contact firstname.lastname@example.org. When in doubt, disclose.
Examples of instances that are NOT considered financial COI:
- Royalties or other technology commercialization proceeds distributed through UNM Rainforest Innovations.
- Income from seminars, lectures, or teaching engagements sponsored by public or nonprofit entities
- Income from service on advisory committees or review panels for public or nonprofit entities.
- Interests in widely held investment funds (i.e., UNM retirement plan) if:
- The investigator does not or cannot exercise control over the fund's financial interests; and
- All the following are true:
- The fund is publicly traded or available (defined as having more than 20 investors);
- Its assets are widely diversified; in general, is the fund has invested no more than five percent (5%) of its portfolio value in the anyone issuer, other than the federal government, and no more than twenty percent (20%) of its portfolio value in any particular economic or geographic sector;
- Interests in blind trusts if the investigator has no knowledge of the trust assets.
In addition, you do not have to report funding by grants supporting your research.
Examples of Non-Financial COI:
Non-financial conflicts of interests are those in which no money is involved, but that might create the appearance of altering the objectivity of your research. The most common of these are:
- Collaboration with your spouse/domestic partner or dependent child on your research
- Service, whether compensated or not, on a board of directors of any entity that does business with UNM · Foreign talents programs, where in return for your expertise, you are given an honorary position
- Any honorary position at a foreign institution or company
- Scholars hosted by your research program whose salary is paid by a foreign government
Once again, this list is not exhaustive, and if in doubt, please disclose!
There are several instances when you need to report:
- Annually through an Annual Disclosure. The disclosure period will be announced by ORIC, but typically coincides with the beginning of the academic year.
- For every sponsored project at the time of proposal submission. This is a change from previous requirements and accommodates the increasing requirement for project-specific disclosures by Federal agencies. Reporting at proposal submission also allows the COI office/committee to complete any required review by the time of award.
- Upon initiating an IRB or IACUC protocol. All personnel named on these protocols must complete a disclosure.
- Within 30 days of acquiring a new reportable interest.
Streamlyne™ electronic research administration suite is the system of record for COI in research at UNM main and branch campuses. To complete a COI disclosure in StreamlyneTM, access the system here. Detailed instructions on completing COI can be found on our Streamlyne™ help page.
Please note that, although we are happy to answer questions about your disclosure at email@example.com, this is not a way to report or update your COI.
An affirmative disclosure of COI triggers a notification to the COI Office that a disclosure needs to be reviewed. At that point, the following happens.
- The disclosure is triaged by the COI office to assign it a risk group based on what is disclosed.
- The disclosure is then assigned to either an administrative, partial committee, or full committee review, based on protocols approved by the COI Committee.
- A determination is made as to whether management of the COI is needed.
- If the COI needs to be managed, the COI Committee issues a management plan or decision memo outlining the requirements for the COI to be managed.
- If a management plan is issued, the investigator and appointed COI Monitor will review, sign and return the management plan. At this point the COI office may report that the conflict is managed, and the investigator is in compliance with requirements.
- The monitor shall report to the COI committee that and how the conflict was managed at least once a year. Failure to monitor the COI can render the investigator out of compliance, therefore it is best that you as an investigator keep track of this process.
Some of your questions may be answered in our COI FAQ.
The friendly COI office staff are here to help you at firstname.lastname@example.org or 277-1045 or 277-5358.
We also hold COI Virtual Office Hours
For in person consultations or consultations outside of office hours, please contact us at email@example.com. We are also willing to come to your department/school/ group meeting/class to present and answer questions about COI.