Conflict of Interest
Conflicts of interest exist when an individual's personal, financial, or other interests could improperly influence execution of his or her University responsibilities. Conflicts are not inherently unacceptable, but must be identified and managed to prevent bias in the scientific process.
The University recognizes that many potential conflicts of interest do not constitute actual conflicts; they may be acceptable with proper oversight and safeguards through managing, reducing, or eliminating the conflict, if necessary.
The conflict of interest and commitment policy of the University serves as a guide to faculty and other employees with principal responsibility for research projects conducted at Michigan Tech.
Beginning in August 2012, some investigators will begin annual disclosures, and after 2015 we hope to have all investigators at Michigan Tech disclose annually. Annual disclosures will be in addition to any disclosures within 30 days of new interests being acquired. Even if you have no financial interests that meet the definition of "significant financial interest", you still need to complete the required training and annual disclosure (checking the box indicating "no financial disclosures"). Michigan Tech will be moving to an "online" disclosure process and all disclosures will be submitted through this process. Until the software is active, paper disclosures will be used.
Notice to all US Public Health Service Investigators (for both funded and pending proposals)
- New regulations pertaining to financial conflicts of interest in research sponsored by the US Public Health Service (PHS) go into effect on August 24, 2012. These regulations, Responsibility of Applicants for Promoting Objectivity in Research for Which Public Health Service Funding is Sought, differ significantly from the regulations they are replacing in the following ways:
- Current regulations require investigators to disclose to Michigan Tech only those financial conflicts of interest relating to their research. The new regulations require investigators to disclose all significant financial interests relating to their University responsibilities. Michigan Tech is then responsible for determining whether or not the financial interest is related to PHS-funded research and poses a potential conflict of interest.
- Current regulations specify a threshold of $10,000 under which disclosure of a financial interest is not required. While the new regulations lower the threshold to $5,000, they require institutions to apply stricter specifications if stricter specifications are in effect at the institution. Michigan Tech will use the $5,000 threshold. All significant financial interests will need to be disclosed.
- Failure by Michigan Tech to report financial conflicts of interest (COI) to the PHS awarding component in a timely manner will necessitate a retrospective review of research to determine whether or not the design, conduct, or reporting of the research was biased.
- New regulations require disclosure no later than at the time of application for PHS funded research.
- The new regulations require all investigators to receive training in the PHS regulations and the Michigan Tech conflict of interest policy and procedures.
- If requested by a member of the public, the Office of Compliance, Integrity, and Safety will provide information about each financial conflict of interest within five days of the request.
- New Michigan Tech procedures have been posted to cover these new regulations. The new procedures do not replace the existing Conflict of Interest procedures, but the new procedures cover conflicts of interest in PHS-funded research at Michigan Tech.
- Please do not hesitate to contact Joanne Polzien (firstname.lastname@example.org) in the Office of Compliance, Integrity, and Safety with questions, concerns, and suggestions.
- Michigan Tech's Conflict of Interest Coordinator is Paul Charlesworth (email@example.com).
Public Health Service Operating Agencies (updated 9/15/2015)
Agency for Healthcare Research and Quality (AHRQ)
Agency for Toxic Substances and Disease Registry (ATSDR)
Centers for Disease Control and Prevention (CDC)
Food and Drug Administration (FDA)
Health Resources and Services Administration (HRSA)
Indian Health Service (HIS)
National Institutes of Health (NIH)
Office of Global Affairs (OGA)
Office of the Assistant Secretary for Health (OASH)
Office of the Assistant Secretary for Preparedness and Response (ASPR)
Office of Public Health and Science
Substance Abuse and Mental Health Services Administration (SAMHSA)
Non-PHS Agencies (updated 3/10/2015)
Alliance for Lupus Research (ALR)
American Asthma Foundation
American Cancer Society (ACS)
American Heart Association (AHA)
American Lung Association (ALA)
Arthritis Foundation (AF)
Juvenile Diabetes Research Foundation (JDRF)
Lupus Foundation of America (LFA)
Patient-Centered Outcomes Research Institute (PCORI)
Susan G. Komen for the Cure