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Potential conflict of interest (COI) situations in research are evaluated based on the following principles and concepts. If a conflict of interest exists, appropriate management is then applied so that the proposed research or related technology transfer activity may occur.
- Disclosure Responsibility - University employees are responsible for reporting, at least annually, their outside interests (and those of the their spouse or domestic partner and dependents) for evaluation of potential conflicts of interest or conflicts of commitment as outlined in federal, U-M, and unit policies.
- Protection of Students/Trainees or Junior Faculty - COI situations are managed so that the academic and research progress of students/trainees, or the employment progress of junior faculty are not affected.
- Protection of Intellectual Property - COI situations involving the ownership, licensing, or optioning intellectual property (IP) are managed so that both the University's and the inventor/developer's rights to benefit from the commercialization of IP are protected per the U-M Regents Bylaw 3.10 and the Office of Technology Transfer policy.
Key COI Concepts
Three (3) key concepts are used to identify whether an outside interest represents a potential COI situation that may require management.
- Is the outside interest significant?
- How is the external entity related to the sponsored research or technology transfer activity?
- What is the individual's association with the external entity and the research or technology transfer activity?
An outside interest is considered significant when the investigator or their family members (see Disclosure Responsibility above) has one or more of the following:
- Received remuneration (e.g., compensation, loans, items of value) from an external entity, whether publicly or non-publicly traded, in the previous 12 months that, when aggregated, exceeds $5,000
- Ownership (i.e., equity, stock, stock options) in an external entity related to your U-M job responsibilities
- Received income from intellectual property (IP) rights and interests (e.g., patents, copyrights, royalties from the rights) including your IP licensed/optioned through U-M and/or other institutions (excludes book royalties)
- A management position (e.g., officer, trustee, director) with an external entity which includes a fiduciary (i.e., legal or ethical) obligation to act in the best interest of the entity
Remember: U-M employees must disclose their outside interests. The applicable COI Office and Committee then determine significance as part of the COI review processes.
An external entity is considered related to sponsored research and/or technology transfer activity at U-M when that entity:
- Sponsors the research (proposal, subcontract)
- Supplies equipment, materials, or services as part of the sponsored research agreement (subcontract, purchasing)
- Commercializes a product for which the research is to evaluate and/or develop further (intellectual property)
- May be impacted financially by the research or technology transfer agreement (management position)
An individual's role on a research project, with a technology transfer activity, or with an external company can both determine if a potential conflict exists and the steps to manage the conflict.