91AV

91AV (TAMUK) provides for a transparent system of disclosure, approval, and documentation of financial interests and activities outside of TAMUK which might otherwise raise concerns about conflicts of interest or conflicts of commitment.

A conflict of interest or commitment is created when personal, financial, or outside interests could unduly influence the design, conduct, or reporting of research, or interfere with the performance of institutional responsibilities. For example, real or perceived conflicts have the potential to influence decisions related to research study design, data collection and analysis, intellectual property ownership, oversight of students and trainees, and use of university facilities and property.

Financial Conflict of Interest

Pursuant to the 91AV;M System Regulation , and TAMUK Rule 15.01.03.K1, TAMUK has the responsibility to identify and manage and reduce or eliminate conflicts of interest that may arise due to financial or other personal interests of the investigator. ALL investigators involved in research at the university, regardless of job title, who are responsible for the design, conduct, or reporting of research or research activities are required to complete a disclosure in Maestro in SSO. Notifications will be sent via email with a link to the Maestro system when disclosure is required:

• within 30 days of initial employment
• prior to the submission of an application for funding
• at minimum annually
• within 30 days of acquisition of a new activity requiring disclosure

Guidance documents regarding FCOI in Maestro can be .

In addition, all investigators who are responsible for designing, conducting, or reporting on research or research activities must also complete training on financial conflicts of interest. Employees will receive automatic notifications with a link to the training. The training is currently available through the A&M System’s  system (TrainTraq Course 2111716), and is required every 4 years.

Policy and Procedure

91AV (TAMUK) rule 15.01.03.K1 Financial Conflicts of Interest in Sponsored Research applies to all faculty and staff who serve as the principal investigator, project director, or other senior/key personnel responsible for the development and conduct of a sponsored project.

 

What do I have to report?

• In short, you must report any significant financial interests that might reasonably appear to be affected by your institutional responsibilities. Specific details regarding the types of interest and dollar thresholds are outlined in TAMUK rule 15.01.03.K1.

What is a financial conflict of interest?

• A number of definitions exist, but the most succinct comes from the latest revision of Title 42 of the Code of Federal Regulations*, which states that a “financial conflict of interest (FCOI) means a significant financial interest that could directly and significantly affect the design, conduct, or reporting of…research.”
• *Source: Promoting Objectivity in Research, .

How often do I have to report?

• Upon submitting a proposal for an externally sponsored grant, cooperative agreement, or contract and once a year thereafter. Additionally, if you gain a significant financial interest during the course of the year, you must report the new interest within 30 days of acquiring it.  

Resources

Numerous federal and private agencies have developed resources related to financial conflict of interest. For additional information regarding agency policies, frequently asked questions, and implementation of conflict of interest policies at other institutions, please visit the Websites listed below.

 on conflicts of interest

, applicable to all projects funded under the Public Health Service, including the NIH

 on Financial Conflict of Interest

 about the NIH’s revised regulations

 on Conflict of Interest