Managed Conflict of Interest Examples

Possible Resolutions to Financial Conflict of Interest or Conflict of Obligation:

• Management Plan

• Modification of the research plan

• Disqualification from participation in the portion of the externally funded research that would be affected by the significant financial interests

• Severance of relationships that create actual or potential conflicts

• Removal of investigator as Principal Investigator/Project Director

Scenarios Determined to be a Financial Conflict of Interest (FCOI) or Conflict of Obligation (CO) and Managed via a Management Plan – this is not an all-inclusive list:

CO: Investigator has an unpaid position (e.g. board member, scientific advisor) with the sponsor.

CO: Investigator is performing research in an area of interest to their startup company.

CO: Sponsor has entered into an agreement with the University for an option to license a pending patent for the technology that is the subject of the research.

FCOI: Investigator receives royalty income from the sponsor for the technology that is the subject of the research.

FCOI: Investigator receives royalty income from the University for the technology that is the subject of the research.

FCOI: Investigator performs a service (e.g. consulting, educational services) for the sponsor of a project.

FCOI: Investigator owns equity or shares in the sponsor.

FCOI: NIH/PHS only – Investigator has received reimbursement or had paid on their behalf travel by the sponsor.

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