Policy Approved: 17 August 2017

Policy Effective: 31 August 2017

I.   PURPOSE AND SCOPE

Oregon State University (“University”) promotes and encourages new and varied collaborations with entities outside of the University.  The University recognizes that as a result of such external relationships conflicts of interest may occur when an individual is in a position to make a decision in the conduct of his or her research, teaching or outreach activities that may result in personal or family gain, financial or otherwise.  Adherence to the highest levels of professional integrity by faculty, staff, students and associated personnel in all their actions is required to avoid or minimize conflicts of interest.

This policy sets forth the obligations of Oregon State University and its employees, students and associated personnel with respect to conflicts of interest that involve University research.

 
What Is the Scope of the Policy?

This policy promotes objectivity in research by establishing expectations and disclosure requirements to ensure that conflicts of interest in research arising from external relationships will be identified and managed or eliminated.  This Policy also reflects the requirements of two federal agencies, the U.S. Public Health Service (PHS) and the National Science Foundation (NSF), because their requirements are specifically established by agency regulation and policy.

In the event that ethical concerns or conflicts of interest not related to research are identified as a result of this Policy’s requirements, the Research Conflict of Interest Officer may refer the issue and relevant information to appropriate University officials.

Other laws and University policies also apply to interactions between University employees and entities external to the University; a list of such policies and their jurisdiction can be found under Additional Information in Section IX.

 
What Is a Research Conflict of Interest at OSU?

A research/financial conflict of interest (“Research Conflict of Interest”) occurs when the design, conduct or reporting of research could be directly and significantly affected by a Significant Financial Interest of an investigator (see Section II for definitions).

The university recognizes that members of our community encounter many types of conflicts of interest. Two examples of commonly encountered conflicts include procurement conflicts in which material goods are obtained non-competitively from a family business and professional conflicts in which one might be asked to provide an objective review of a manuscript or proposal prepared by a colleague, student, mentor, or recent collaborator.  This policy does not apply to these types of conflicts. This policy pertains strictly to research/financial conflicts of interest.

This policy recognizes that relationships exist that could result in a Research Conflict of Interest.  The intent of this policy is to identify such relationships and manage them by defining the boundaries within which Research Conflicts occur while allowing investigators to proceed with their research.  The primary goal is to maintain objectivity in research by establishing standards to ensure that there is no reasonable expectation that the design, conduct, or reporting of research will be biased by a Significant Financial Interest of an investigator. 

 
What Does the Policy Call For?
  1. Disclosure by investigators of significant financial interests (see Section III).
  2. Review of disclosures by appropriate individuals and management or elimination of identified Conflicts of Interest (see Section IV).
  3. Training of investigators on this Policy, their responsibilities regarding disclosure, and federal regulations on Conflicts of Interest (see Section V).

 

II.   DEFINITIONS

  1. “Research Conflict of Interest” or “Research Conflict” means a Significant Financial Interest that could directly and significantly affect the design, conduct or reporting of research.
  2. “Investigator” means any individual who is responsible for the design, conduct or reporting of University research.  “Investigator” is not defined by faculty rank or title and can include any individual affiliated with University research.
  3. “Research Conflict of Interest Officer” or “RCOI Officer” means the person appointed by the Vice President for Research to review all disclosures and identify and resolve Conflicts of Interest.
  4. “Research Conflict of Interest Committee” or “RCOI Committee” means a committee made up of OSU faculty and staff appointed by the Vice President for Research and serving in an advisory capacity to the RCOI Officer.
  5. “Family” or “Family Member” means:
    • (a) the individual's spouse or domestic partner, and
    • (b) the dependent children of the individual or the individual's spouse or domestic partner
  1. “Significant Financial Interest” means a financial interest consisting of one or more of the following interests of the individual and his or her family:
    • (a) Remuneration (salary and any other payment for service, e.g., consulting fees, honoraria, paid authorship, etc.) received from a single entity in the last 12 months valued at $5,000 or more;
    • (b) Any equity (stock, stock options or other ownership interest) valued at $5,000 or more in a single publicly traded entity;
    • (c) An aggregate of (a) and (b) that is $5,000 or more for a single publicly traded entity;
    • (d) Any equity in a non-publicly traded entity;
    • (e) Income related to intellectual property rights and interests that is valued at $5,000 or more.

Significant Financial Interest does not include (i) salary, royalties, or other remuneration from the University; (ii) income from investment vehicles, such as mutual funds or retirement accounts, where the individual or family members do not directly control the investment decisions; or (iii) income from seminars, lectures, teaching engagements sponsored by, or service on advisory committees or review panels for, a Federal, state or local government agency, an institution of higher education, an academic teaching hospital, a medical center, or a research institute that is affiliated with an institution of higher education.

 

III.   REPORTING

On an annual basis, disclosure of outside activities and Significant Financial Interests via the Research Conflict of Interest Disclosure Form is required by:

  1. Professorial faculty, Research Associates, and Post-Doctoral Fellows/Scholars
  2. Individuals who serve or intend to serve as an investigator on a sponsored project, including but not limited to Professional Faculty, Faculty Research Assistants, Senior Faculty Research Assistants, Instructors, and Emeritus, Courtesy and Visiting Faculty
  3. Other individuals as identified by the Research Conflict of Interest Officer, a college dean or unit head

The Disclosure Form will solicit information that allows the University to determine whether the individual has a Research Conflict of Interest.  Within the constraints imposed by state law, Disclosure Forms will be kept confidential.

Individuals required to report annually must also update their Disclosure Form within 30 days of discovering or acquiring a new Significant Financial Interest and when significant changes occur in the circumstances of a previously reported activity.  In addition, any other individual engaged in research or with the intent to engage in research who has a Research Conflict of Interest must disclose the activity that gives rise to the Research Conflict of Interest when it first arises or is discovered. 

 
Requirements Specific to Sponsored Research

Before submission of an application for funding, principal investigators must disclose any Significant Financial Interests of any investigators on the project that would reasonably appear to be affected by the proposed research for which funding is sought.  Before funds are spent, the University must review the disclosure, determine whether there is a Research Conflict and, if so, manage or eliminate it.

Investigators who receive funding from the Public Health Service (PHS), including funding from the National Institutes of Health (NIH), must also report to the RCOI Officer the occurrence of any reimbursed or sponsored travel that is related to their institutional responsibilities unless the travel is reimbursed or sponsored by Federal, state or local government, an institution of higher education, an academic teaching hospital, a medical center, or a research institute that is affiliated with an institution of higher education.  The disclosure must include the purpose of the trip, the identity of the sponsor/organizer, the destination and the duration.  The RCOI Officer may determine that additional information is needed, including a determination or disclosure of monetary value.

 

IV.   REVIEW AND MANAGEMENT

The Research Conflict of Interest Officer or designee will review Disclosure Forms and other information considered relevant to evaluate whether a Research Conflict of Interest exists and to manage or eliminate the conflict.  The RCOI Officer shall determine the appropriate resolution of a Research Conflict of Interest.  In cases where a Research Conflict of Interest exists, a plan to eliminate or manage the Research Conflict will be created by the RCOI Officer with input by the investigator.

At the request of the RCOI Officer, the Research Conflict of Interest Committee or other individuals as identified by the RCOI Officer will advise the RCOI Officer on any issues of actual, potential, or perceived Research Conflicts of Interest. 

The RCOI Committee will serve in an advisory capacity to the RCOI Officer and represent the diversity of academic and research/scholarship disciplines and administrative functions of the University.  An Executive Committee of the RCOI Committee will be comprised of the Chair, Vice Chair, RCOI Officer and RCOI Administrator and will provide leadership for the RCOI Committee. Faculty members are appointed to the RCOI Committee by the Vice President for Research.

 

V.   TRAINING

All individuals required to submit a Disclosure Form on an annual basis must complete training on this Policy, their responsibilities regarding disclosure, and federal regulations on research conflicts of interest. Investigators who receive funding from PHS must complete such training every four years; immediately when the University revises its Conflict of Interest Policy; when an investigator is new to the University; and when the University finds an investigator is not in compliance with this policy or an applicable management plan.  All other individuals required to submit a Disclosure Form on an annual basis must complete training at least once.

 

VI.   APPEALS

An employee may appeal a decision of the Research Conflict of Interest Officer to the Vice Provost for Academic Affairs.  If the Research Conflict involves externally funded research, the Vice Provost for Academic Affairs will consult with the Vice President for Research.

 

VII.   SANCTIONS

Failure to comply with this policy may subject an employee to sanctions up to and including dismissal, in accordance with OSU Policy "Conditions of Service 580-021".

When sanctions result from a Research Conflict of Interest that includes an externally funded research or scholarship project, the University will take action legally required by the funding sponsor.

 

VIII.   INSTITUTIONAL REQUIREMENTS FOR PHS AND NSF

The Public Health Service of the United States Department of Health and Human Services (PHS) and the National Science Foundation (NSF) have specific requirements for identification, disclosure and management of conflicts of interest arising in research funded by those agencies.  The University will meet the requirements as defined in 42 CFR Part 50, Subpart F (Responsibility of Applicants for Promoting Objectivity in Research for which PHS Funding is Sought), 45 CFR Part 49 (Responsible Prospective Contractors), and the NSF Conflict of Interest Policies, Chapter V: Grantee Standards, Policies and Procedures Guide.

 

IX.   ADDITIONAL INFORMATION

Questions about this Research Conflicts of Interest Policy should be directed to the RCOI Officer.

Other policies relating to conflicts that are applicable to University employees and investigators include:

  1. Employment & Supervision of Immediate Family Members Policy, OSU Office of Human Resources
  2. Employment of More than One Member of a Household Policy, OSU Policy "Employing Household Members, Faculty 580-022"
  3. Conflict of Commitment Policy, OSU Academic Affairs
  4. 104-001: Declaration of Conflict or Potential Conflict of Interest, OSU Procurement and Contract Services (PaCS) Policy & Procedure Manual
  5. Oregon Government Ethics Law, Oregon Revised Statutes, Chapter 244
  6. Higher Education potential conflict of interest, Oregon Revised Statutes, 351.067
  7. Outside Employment and Activities; Conflict of Interest, OSU Policy "Conditions of Service 580-021"