Take home message: If it is possible that your outside interests could conflict or appear to conflict with the University’s interests, you have a potential (or perceived) conflict that should be disclosed to your supervisor for discussion or management.
- The Standard Practice Guide on Conflicts of Interest and Conflicts of Commitment(SPG 201.65-1) sets out the responsibilities of all U-M faculty and staff relating to actual or potential conflicts, and the University’s framework for addressing them. For faculty, see also Part 9.G of the Faculty Handbook for a summary of faculty responsibilities and resources relating to conflicts of interest and conflicts of commitment (COI/COC).
- Each U-M unit has its own Unit Policy on Conflicts, including the U-M Health System, Nursing School, Pharmacy School, Dentistry School and School of Public Health, all of which are viewable from the Provost’s website.
- The UMHS Outside Interests and Conflicts of Interest Policy applies to all UMHS house officers, faculty and staff: you can review the UMHS Policy (internal UMHS networks only), or view it here if you are outside the UMHS network.
- There are many helpful resources on the Health System page on conflicts of interest and outside interest disclosures (viewable on U-M networks only), including a tools and education page that features example scenarios and FAQs. See also the UMHS Compliance Office page on conflicts (U-M networks only), the Regulatory Affairs Office and the Provost’s website related to conflicts of interest and commitment.
- If you are involved in research, read about conflicts of interest in sponsored research and technology transfer agreements, which includes a summary of the various U-M and sponsor policies related to research conflicts, and useful examples of potential conflict situations for different research scenarios. In addition, the Human Subjects Operations Manual (Part 9) summarizes the conflict of interest obligations and processes for human subjects research, and the Medical School Institutional Review Board (IRBMED) also has standard operating procedures (see Part 9) that outline their process for handling conflicts and link to relevant policies and guidelines.
- For those who conduct research funded by the National Institutes of Health (NIH) or other Public Health Service (PHS) agencies: new regulations are coming into effect on August 24th, 2012 that will significantly change the way you disclose your interests and manage your conflicts. Read more about this change at U-M Research: PHS Policy Change.
- There is a training module on COI contained within PEERRS (U-M’s Program for Education and Evaluation in Responsible Research and Scholarship).
- In the human subjects and clinical research field, conflict of interest situations often require committee approval by a COI committee: For instance, the Office of the Vice President for Research (OVPR) Conflict of Interest Committee oversees conflicts connected to sponsored research projects or technology transfer, and the Medical School COI Board review and approve certain conflicts in the U-M Health System.
- Some conflict of interest situations require Regental approval: Under Michigan law, U-M may not contract, directly or indirectly, with its employees without the approval of the Board of Regents. “Indirect contracting” can include being an employee of an outside company, owning large amounts of stock in an outside company, or being a member of the outside company’s board of directors. For more information, contact Procurement Services or, if the contract involves research or intellectual property licensing, the Office of the Vice President for Research.
- In the busy and interconnected academic and clinical community, conflicts of interest and commitment just happen – and they don’t mean you are a bad person! The important thing is that you know how to identify potential conflicts, disclose them to your dean, chair or director, and work out how to manage them in a way that doesn’t compromise you or the University.
- Potential conflicts are just as critical as actual conflicts – identifying conflicts before they actually happen puts you and the University in a much better position to avoid and/or deal with them.
- Just because you’re asked to disclose a financial interest, doesn’t mean you’re going to lose your job! Disclosures are required under various laws, accreditations and grant requirements – and once they are disclosed, they can be assessed for potential conflicts, and managed appropriately. A failure to disclose something that puts you in conflict will have much more serious consequences for you than an open disclosure followed by ongoing management.
- There are great examples and resources on the UMHS conflicts page, including lists of activities that could lead to conflict and example management plans.
- Perception is as important as reality when it comes to conflict – the appearance of conflict can be very damaging to your reputation and the University’s reputation, even if you don’t believe there to be a conflict. Think about how any situation might look to outsiders when assessing your behavior. If it is possible that your outside interests could conflict or appear to conflict with the University’s interests, you have a potential (or perceived) conflict that should be disclosed to your supervisor for discussion or management.
- If you or your outside company are entering a contract with U-M, the contract may require approval by the Board of Regents. Check with Procurement Services or (for research contracts) the Office of the Vice President for Research before finalizing such a contract.
For advice on specific conflicts, you should talk in the first instance to your dean, chair or director. You could also talk to your unit’s HR representative, who can give you guidance on your unit’s conflicts of interest and commitment policy and procedures.
You could also seek advice from the Medical School COI Board or Medical School Institutional Review Board (IRBMED).
For advice or questions about the new NIH/PHS conflict of interest regulations, contact theMedical School Office of Regulatory Affairs (for Medical School employees) or Office of the Vice President for Research.
For advice on policy implementation relating to conflicts, or for general guidance about managing conflicts of interest and commitment, contact the Provost’s Office – by emailing them or using one of the other contact options listed at the bottom of the Provost’s conflicts site. The Office of the General Counsel also maintains FAQs on Conflicts that may answer your questions.
Established 3/4/11, last updated 3/7/17 – Contact us if you believe any information is incorrect or outdated