Conflict of Interest

Conflict of interest (COI) involves circumstances where an individual's professional actions or decisions at the University could be influenced by considerations of personal gain, usually of a financial nature, as a result of interests outside their University responsibilities. The central theme in addressing COI is transparency, and the first step is disclosure of the interest to the appropriate University administrative office.

Financial conflict of interest in research involves situations in which a researcher has a significant financial interest that may compromise, or have the appearance of compromising, professional judgment in the design, conduct, or reporting of research. A significant financial interest could include personal compensation from industry, equity interest or a management role in a company, or royalties generated from intellectual property rights.

Financial conflicts of interest are common and even inevitable at research universities. Collaborations between academic researchers and industry can provide mutual benefit by contributing to a university's research mission and helping to focus the research directions of industry. Industry/researcher collaboration is accomplished by individual consultation and/or sponsored research.  Universities are also responsible for stimulating economic development and transferring discoveries to the private sector. Universities commercialize their technologies by licensing discoveries to industry or to companies started by academic inventors.

All of these situations can create opportunities for researchers to receive financial rewards related to their research. With the opportunities comes risks that the direction of research will be affected, the objectivity of the data will be compromised, and the interpretation of research results will be skewed. As a researcher, you might not consider that your financial interest would pose these risks, but it can create that perception. This perception of bias can be as damaging to the researcher and the institution as actual bias.

In most situations, conflicts of interest and commitment can be managed to help protect the credibility of the work being done and the reputation and integrity of our people and the University, and the first step in helping manage those conflicts is disclosure. Most of the recent enforcement actions by the federal government have resulted from failure by the individuals in question to disclose their relationships and seek an appropriate management plan.

As a steward of the public trust, San Diego State University is obligated to ensure its research involving human subjects is carried out with integrity, open inquiry, and rigorous analysis, free from potential financial conflicts of interest that might affect the sound judgment of its faculty, staff, and students. When financial interests of the University or its University officials exist and create real or potential bias to the outcome of its research, an institutional conflict of interest exists.

For example, the University or one of its officials may have a financial interest in a company sponsoring research covered by this policy or may hold a proprietary interest in a product that is the subject of the research. When such research involves human subjects and the institution maintains its financial interest, the conflict of interest is presumed to be unacceptable. Such research will only be allowed to proceed at the University if there are compelling circumstances justifying the research to be conducted despite the presence of the financial conflict.

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 (without 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 participants 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.