Conflict of Interest

Financial Conflict of Interest, also referred to as FCOI or simply Conflict of Interest or COI, is an issue of rising concern with the Department of Health and Human Services (DHHS).  

DHHS has revised its regulations and requires all institutions receiving DHHS funding to revise their institutional policies on the topic, as of August 24, 2012. 

Please see Radford University's Conflict of Interest Policy, as required to comply with current federal regulations, 42 CFR 50.603-50.607.

Also, please note that annually and every time a new financial interest is determined or acquired, a Financial Conflict of Interest Disclosure Certification Form must be completed and sent to the Sponsored Programs and Grants Management Office.

Please contact the Research Compliance Office or Sponsored Programs and Grants Management Office for more information, if desired.

Types of Conflict

Conflict of Interest/Financial Conflict of Interest

A potential Conflict of Interest (COI)/Financial Conflict of Interest (FCOI) exists whenever personal, professional, commercial, or financial interests or activities outside the university have the possibility (either in actuality or in appearance) of (1) compromising a member of Radford University’s judgement; (2) biasing the nature or direction of scholarly research; (3) influencing a faculty or staff member’s decision of behavior with respect to teaching and student affairs, appointments and promotions, uses of University resources, interactions with human subjects, or other matters of interest to the University; or (4) resulting in personal or family member’s gain or advancement at the expense of the University.

Examples:

• Assigning a textbook for which you receive royalties as the required book for a course you teach.
• Accepting gifts from a student whom you must evaluate.
• Receiving royalties or other licensing proceeds from intellectual property you invented and are evaluating or further developing as part of your institutional responsibilities.

Conflicts of Interest in Research

Occurs when an employee who is conducting research has a financial interest which could cause bias that effects the design, conduct, or reporting of his/her research, for instance, a financial interest in a sponsor or the research, or in the manufacturer of a product or device used in the research. If the financial interest could reasonably be perceived to affect the research directly and significantly, it must be reported even if its dollar amount or percentages is minimal.

Examples:

• Accepting gifts or gratuities from companies doing business or sponsoring one's research at Radford University.
• Accepting honoraria over fair market value for lectures on behalf of companies, for instance for a company whose economic or political interests are affected by an investigator's research.
• Performing research for a company in which the investigator has a financial interest.
• Accepting a paid consultancy with a company having an interest in your research.
• Using students to perform services for a company in which you have a financial interest.
• Providing privileged access to information developed with Radford University or independent sponsorship to another entity in which you have a financial interest.
• Providing or receiving financial bonuses from a research sponsor for meeting subject recruitment targets or achieving stated results.
• Holding office or membership on a board or committee of an entity supporting your Radford University research.
• Holding equity interests, including stock options, in an entity which supports your Radford University research.
• Imposition of restrictions on the actions of students or trainees, including disclosure of research findings, at the request of a sponsor or financially interested company.

Conflict of Commitment

A potential Conflict of Commitment (COC) exists when a Radford University community member’s external relationships or activities have the possibility (either in actuality or in appearance) of interfering or competing with the University’s educational, research, or service missions, or with that individual’s ability or willingness to perform the full range of responsibilities associated with his or her position.

Examples:

• A history professor writes historical fiction novels which consume 40 hours per week of their time, and the impact on their institutional responsibilities is noticeable.
• A music professor performs with a traveling folk music group, which sometimes conflicts with instructional duties.

COI Training Resources

Radford University subscribes to the CITI Training program platform to provide researchers with the required FCOI related training.

Most PHS funded awards require that researchers receive FCOI training every three (3) years. The CITI Conflicts of Interest, Financial Conflict of Interest course satisfies this requirement.