What is a significant financial interest?
A significant financial
interest is anything of monetary value, including but not limited to,
salary or other payments for services (e.g., consulting fees or honoraria);
equity interests (e.g., stocks, stock options or other ownership interests);
and intellectual property rights (e.g., patents, copyrights and royalties from
such rights).
Some exclusions
apply under the Federal Regulations. However, UTSA requires disclosure of ALL
financial interests regardless of value or compensation.
What is conflict of commitment?
Conflicts of Commitment,
which may also be called conflicts of effort or conflicts of obligation, occur
when the extent of time spent on secondary or external activities is so
substantial as to interfere, or appear to interfere, with the individual's
obligations (of teaching, research, or service) to the University.
Who must disclose financial interests?
All UTSA Researchers
(employees) engaged in funded or unfunded research as well as sponsored
activities/programs so this includes post docs, graduate assistants, and others
having direct responsibility for the design, conduct or reporting of research,
and any other person specified by a Department Chair or Dean. Disclosures include information on financial
interests for themselves and their spouse/domestic partner, dependent children
and other persons in their household. This includes those individuals who will
be named in an informed consent form for projects involving human research
subjects.
Where are financial disclosures submitted?
Disclosures of Financial
Interests Related to Research & Intellectual Property Forms are generally
submitted to the respective Dean, or his/her designated appointee. The Dean's
Office forwards all completed Disclosure Forms to the Office of Research
Integrity & Compliance.
In addition, when a
funding proposal is submitted to the Office of Sponsored Programs, the proposal
routing sheet will contain a statement certifying that all current Disclosure
Forms are on file with The Office of Research Integrity & Compliance. The
Disclosure Form must be updated
as new reportable significant financial interests are obtained and/or
identified.
Disclosures in which
significant financial interests are found must be reviewed and approved before
the University can set up award (grant) accounts.
If I disclose a possible conflict of interest, what happens
then?
The Office of Research
Integrity & Compliance will conduct pre-reviews of all forms with positive disclosures
and gather all necessary information. The Committee on Conflict of Interest in
Research &
Intellectual Property will
review and assess whether the conflict can be eliminated, reduced or managed.
If a management plan is put in place, the project will be monitored and other
documentation may have to be provided (i.e. consulting agreements, IRS tax
forms) to ensure the management plan is being adhered to. (See Procedures for
Declaring Potential Conflicts and Obtaining Approval for Management Plan)
This committee is an
independent faculty body that is advisory to the Sr. Associate VP for Research
Administration.
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Conflict
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Example
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Inappropriate enrollment of study subjects
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Research subjects enrolled who do not meet study criteria
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Flawed informed consent process
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Study subjects not adequately informed of all risks in the consent
process
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Inadequate standard of patient care
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Clinical decisions driven by research priorities rather than patient
needs
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Adverse events not appropriately reported /managed
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Adverse events not reported within time required
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Conflict
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Example
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Research Responsibilities
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Competitive grants not pursued, research results not published in a
timely manner
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Teaching Responsibilities
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Trainees research restrained/driven by company priorities, limited
contribution to university's teaching mission
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Clinical Responsibilities
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Insufficient time devoted to providing clinical care, quality of care
compromised
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Administrative Responsibilities
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Administrative duties not accomplished in a timely manner
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Community Service Responsibilities
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Lack of participation in community service activities at level
expected
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Conflict
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Example
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Research for outside entity conducted in university facilities
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Using campus classrooms or laboratories
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Research for outside entity conducted by university personnel
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Having students, fellows, trainees, faculty or staff conduct research
for outside entity
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Research for outside entity conducted with university equipment
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Using campus computers, printers, lab equipment, etc.
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University research resources provided to outside entity
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Intellectual property inappropriately transferred to outside entity
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