Conflict of Interest

Conflict of interest (COI) refers to circumstances in which an individual's professional actions or decisions at the University could be influenced by considerations of personal gain, usually financial in nature, arising from interests outside their University responsibilities. The central principle in addressing COI is transparency, and the first step is disclosing the interest to the appropriate University administrative office.

A financial conflict of interest in research occurs when a researcher has a significant financial interest that may compromise, or appear to compromise, their professional judgment in the design, conduct, or reporting of research. A significant financial interest may include personal compensation from industry, an equity interest or management role in a company, or royalties generated from intellectual property rights.

Financial conflicts of interest are common and, in many cases, unavoidable at research universities. Collaborations between academic researchers and industry can provide mutual benefits by advancing a university's research mission while helping to guide industry research and development efforts. These collaborations may take the form of consulting arrangements, sponsored research, or other partnerships. Universities also play an important role in stimulating economic development and transferring discoveries to the private sector. They often commercialize technologies by licensing discoveries to existing companies or to startup companies founded by academic inventors.

Each of these situations can create opportunities for researchers to receive financial rewards related to their work. However, these opportunities also carry risks. The direction of research may be influenced, the objectivity of data may be compromised, or the interpretation of results may be biased. Even if a researcher believes that a financial interest does not affect their judgment, it can still create the perception of bias. This perception can be just as damaging to the researcher and the institution as actual bias.

In most cases, conflicts of interest and commitment can be effectively managed to protect the credibility of the work being conducted and to preserve the reputation and integrity of both the University and its researchers. The first step in managing these conflicts is disclosure. Notably, many recent federal enforcement actions have stemmed from individuals' failure to disclose relevant relationships and obtain an appropriate conflict management plan.

As a steward of the public trust, San Diego State University is obligated to ensure that research involving human subjects is conducted with integrity, open inquiry, and rigorous analysis, free from financial conflicts of interest that could compromise the sound judgment of its faculty, staff, and students.

An institutional conflict of interest exists when the financial interests of the University or its officials create an actual or potential bias in the design, conduct, review, or outcome of research.

For example, the University or one of its officials may have a financial interest in a company sponsoring research covered by this policy, or the University may hold a proprietary interest in a product that is the subject of the research. When such research involves human subjects and the institution retains its financial interest, the conflict of interest is generally presumed to be unacceptable.

In these circumstances, the research may proceed only if compelling reasons justify conducting the study despite the presence of the financial conflict of interest.

Outside Activities That May Create a FCOI

• Holding equity interests (i.e., stock) in an entity that supports your SDSU research
• Holding any of these positions in an entity that supports your SDSU research:
  • Office or membership on a board of committee
  • Director, officer, partner, trustee, employee, or management (with or without income or equity)
  • Founder, co-founder, or shareholder
• Accepting the following from an entity that supports your SDSU research:
  • Travel reimbursement from a sponsor to attend board meetings.
  • Honoraria for lectures at companies whose financial interests are affected by your University research.
  • Income, gifts, or loans
  • Consulting income where the consulting activity could reasonably appear to be related to the research project.
• Financial interest in a business entity that:
  • Develops, manufactures, or improves a product or offers services related to the research project.
  • Will act as a vendor, subcontractor, lessor, or other participant on the research project.
  • Is related to intellectual property in which the investigator is named as an inventor if the research project could reasonably appear to be affected by the interest.