Q: What is a conflict of interest?
A: A conflict of interest in research refers to a situation in which significant financial interest or other personal considerations may compromise or could appear to compromise a research’s professional judgment or integrity.
Q: What is a financial conflict of interest in research?
A: A financial conflict of interest in research is a situation in which an objective layperson might perceive that an individual’s financial relationships might compromise the individual’s professional judgment in conducting, analyzing or reporting research. For example, an investigator might have a financial conflict of interest if he or she is a consultant to the company sponsoring research in his or her laboratory. Another example is a faculty member who owns significant equity in a company whose product he or she wants to test.
Q: Who must disclose? What financial interests must be disclosed?
A: Anyone with principal responsibility for a research project (under state regulations) and principal investigators, co-principal investigators and other individuals who have responsibility for the design, conduct or reporting of a project (under federal regulations) must disclose financial interests in non-governmental entities that are supporting the research.
Research support can be in the form of grants, contracts, subcontracts or subgrants, gifts, donated equipment or supplies and some material transfer agreements. Additionally, disclosures of financial interests related to research and research training are required when the research is supported by certain federal agencies, including the National Institutes of Health and the National Science Foundation, or by sponsors who require review under federal guidelines.
When the grant application is submitted, a conflict of interest disclosure form (700-U or NSF or PHS financial disclosure forms) should be used to disclose financial interest and submitted with the proposal to the Sponsored Projects Office.
Q: Does a financial interest related to research doom the research project?
A: No. A financial interest does not automatically constitute a conflict that precludes the acceptance of research support. The UC Merced Conflict of Interest Committee has determined that financial interests must be assessed within a specific factual context, and most conflicts of interest can be reduced, eliminated or managed.
Q: Who reviews financial disclosures?
A: The campus Desginated Official or Conflict of Interest Committee review positive disclosures of financial interests to determine whether these interests constitute significant conflicts that must be eliminated, reduced or managed before research support can be accepted. If research support may be accepted, the Official or Committee then also determines an appropriate strategy for management of any significant conflict.
Q: Why are there separate procedures for disclosing financial interests under awards from non-governmental entities (profit and non-profit) and government agencies?
A: There are separate State of California laws and Federal regulations each with its own set of requirements for disclosure and review, and its own reporting thresholds.