Research Conflicts of Interest
UTHealth is committed to ensuring that financial interests of investigators and the institution do not affect, or appear to affect, the design, conduct or reporting of research or compromise the protection of human subjects. Therefore, members of the university community conducting or supervising research or educational activities using public or private funding from any source must disclose potential conflicts of interest and, when appropriate, work cooperatively with the Executive Vice President of Academics & Research Affairs ("EVPARA) to develop and implement plans to manage, reduce or eliminate conflicts of interest. The approval of The University of Texas ("UT") System Office of General Counsel and Executive Vice Chancellor for Health Affairs is also required for employees who are pursuing sponsored research agreements or licensing agreements for intellectual property with entities where they have equity or serve as a board member, officer or key employee.
Recently, the Policy for Research Conflicts of Interest (RCOI) known as HOOP 94 has been modified in response to the national regulatory requirement calling for more transparency and accountability among all institutions that receive federal funding for research (42 CFR 50). In conjunction, UT System revised their policy for disclosure, management, and reporting of significant financial interests (UTS 175) and requires all UT System health institutions to meet UT System and federal regulatory standards by early Spring 2011. To maintain compliance with these regulatory mandates, The Office of the Provost and Research Conflicts of Interest Committee have worked to develop a plan that will allow us to meet these mandatory requirements while minimizing the adverse impact on our researchers and their research programs.
Four changes to our existing policies will impact most research teams |
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| The scope for RCOI declarations has been expanded to include all funded research projects; and all key study personnel. The threshold for reporting significant financial conflicts of interest (SFCOI) for outside activities has been decreased from $10,000 to $5,000; and definition of SFCOI includes gifts from a single entity valued more than $250 during the reporting period. There is a new mandatory training requirement for all key study personnel identified on a project. This training certification has to be renewed every two years. All financial conflicts of interest in research that are deemed by the Research Conflicts of Interest Committee to require a Management Plan must be posted on a publically accessible website that must be maintained by the University. |
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NOTE: HOOP 94 deals exclusively with financial interests related to research. Conflicts of interest related to an employee’s status as an employee of the State of Texas are discussed in HOOP Policy 20 Conflicts of Interest and Outside Activities. This policy does not necessarily preclude the conduct of research where a conflict of interest, or potential conflict of interest, is present. Within the process, there may be situations where the research is allowed to proceed if it is of sufficient importance and there are compelling circumstances.
