Disclosure of Competing Interests
Conflicts of interest (COI) are "situations in which financial or other personal considerations
may compromise, or have the appearance of compromising, an investigator's judgment
in conducting or reporting research." AAMC, 1990
"A conflict of interest in research exists when the individual has interests in the
outcome of the research that may lead to a personal advantage and that might therefore,
in actuality or appearance compromise the integrity of the research." NAS, Integrity
in Scientific Research.
While AU desires to promote collaborations for our faculty with both government and
non-government entities, we recognize that these collaborations may create conflicts
of interest in the research arena. In order to meet federal and state requirements
and to ensure that AU maintains adequate oversight and transparency, our policy offers
numerous alternatives for resolution of conflicts of interest including public disclosure,
monitoring, modification of the research plan, disqualification of the researcher
from participation, and divestiture of any financial interest.
Please Note: Conflicts of interest must be declared at least annually or more frequently when
new conflicts arise.
Potential Conflicts Requiring Disclosure
Disclose all relationships with outside entities and the receipt of anything of monetary
value (e.g., consulting fees, honoraria, salary, royalties, equity, stock, stock options)
that meet the following criteria:
- Could reasonably appear to the general public as related to your institutional responsibilities
(professional duties on behalf of AU), and
- Were held or received in the past 12 months by you or
- Were held or received in the past 12 months by a related person (spouse/domestic partner,
dependent children/step-children, and other related persons with whom you are financially
Disclose all "Significant Financial Interests" in the following categories:
- Renumeration (including payments, income, consulting fees, honoraria, paid authorship, etc.) only
- The total of payments and equity held exceeds $5,000 if the source is a publicly traded
- Payments exceed $5,000 if the source is a non-publicly traded entity (such as a start-up
- Equity (including stock, stock options, shares, and other ownership interests) only if:
- The total of remuneration and equity held exceeds $5,000 if the source is a publicly
traded entity OR
- The equity is held in a non-publicly traded entity.
- Travel reimbursements and sponsored travel(including reimbursements and sponsored travel paid on your behalf) as follows:
- If you have requested or received any funding from NIH/PHS in the past 12 months,
disclose all travel payments.
- Intellectual property rights (e.g., patents, copyrights) and an royalties and other payments
Items Not Viewed as Conflicts
Some activities, interests, and items that do not appear to be related to your professional
responsibilities on behalf of AU do not require disclosure. They include:
- Salary, royalties, travel reimbursement, or other remuneration paid by AU
- Income from seminars, lectures, teaching engagements, service on an advisory committee
or review panel
- Travel reimbursements or sponsored travel from: U.S. federal, state, or local governments, U.S.
institutions of higher education, academic teaching hospitals, medical centers, or Research
institutes affiliated with a U.S. institution of higher education
- Income from certain investment vehicles (e.g., mutual funds, retirement accounts)
if you do not directly control the investment decisions.