Conflict of Commitment Policies for COGR Member Institutions

Last Edited 11/8/19

Hospitals

Children's Hospital of Philadelphia

The Conflict of Interest Policy  also covers conflict of commitment.  We are a free standing academic medical center with many of our physicians and researchers having an academic/teaching affiliation with a separate institution (University of Pennsylvania School of Medicine), with its own policies on conflict of commitment that apply to faculty’s external activities.

Partners Healthcare

Policies on Interactions with Industry and Other Outside Entities

 

Universities

Auburn University

Conflict of Interest Policy

Our CoC policy is combined with our COI policy.

This policy applies to all Auburn University Employees including main campus, Auburn University at Montgomery, Alabama Cooperative Extension System (ACES), and Alabama Agriculture Experiment Station (AAES). Other information to note, this policy was implemented in March 2019 and in October 2019 we implemented a university-wide electronic COI/COC disclosure process for all full-time employees. We joined efforts with Research Compliance so that faculty would only need to complete one COI questionnaire. Our question 1 includes relevant research-related COI disclosures mandated by federal regulations (PHS, NSF, etc.) if the employee is engaged in sponsored research and related activities. Our question 2 is aimed at conflict of commitment, asking for the time commitment/schedule with the outside activity and whether any university resources are used to engage in the outside activity.

 

Brown University

Conflict of Interest/CoC Policy

COI in Research is addressed here

 

California Institute of Technology

Caltech doesn’t have a separate conflict of commitment policy.  However, that topic is addressed in the Caltech Conflict of Interest policy, in a Staff Personnel Memorandum, and in a Policy from the Dean of Graduate Studies that applies to grad students at Caltech.  Links to these documents are provided:

1)  The Caltech Policy on Conflict of Interest includes conflict of commitment.  One of our questions in our annual disclosure is specifically directed towards conflicts of commitment for all staff and faculty.

2)  The Staff Personnel Memorandum on Outside Activities covers conflict of commitment for Staff.

3)  Conflict of interest and conflict of commitment are covered for graduate students.

 

University of California - System-wide

1)  APM 671, Conflict of Commitment and Outside Activities of Health Sciences Compensation Plan Participants

2)  APM 025, Conflict of Commitment and Outside Activities of Faculty Members

3)  Conflict of interest and conflict of commitment policies are separate.

Academic Personnel Manual chapter 671 applies to faculty who are members of a Health Sciences Compensation Plan in the Schools of Medicine and Dentistry.  Academic Personnel Manual chapter 025 applies to all other faculty.

 

University of Chicago

Our Conflict of Commitment Policy is combined with our Conflict of Interest Policy and applies to the University.

University of Chicago Medical Center has a different policy.

 

Cornell University

Our Conflict of Commitment policy is Cornell University Policy 4.14: Conflicts of Interest and Commitment (Excluding Financial Conflict of Interest Related to Research).

The policy is separate from our Financial Conflict of Interest Related to Research Policy, though some CoC information is captured through the FCOI reporting process. Both policies cover the Cornell University Ithaca campuses, as well as Weill Cornell Medicine.

 

Louisiana State University

Conflict of Commitment Policy

LSU has a separate Financial Conflict of Interest Policy (FCOI) that applies only to this campus.

The conflict of commitment policy applies to all of LSU.  It is a “system” wide policy.

 

University of Michigan

Conflict of commitment is covered through several policies:

1)   The University of Michigan (U-M) posts general information about conflicts of interest (COI) policies and practices here
2)   U-M’s standard practice guide (SPG 201.65-1) serves as a central policy for both COIs and COCs.
3)   Implementation of the SPG 201-65-1 is handled by individuals Colleges/Schools/Institutes.  Implementation plans are posted here
4)   U-M’s Institutional COI policy is posted here
5)   U-M has a separate Policy for Identification and Management of Conflicts of Interest in Research and Technology Transfer (under revision) that includes outside interest disclosure requirements.

 

Michigan Technological University

Conflict of Commitment is addressed in Michigan Tech's Conflict of Interest Policy which is in Section 4 of our Board of Trustees Policy Manual.

 

University of Maryland College Park

Here are the University of Maryland College Park policies and procedures for Conflict of Commitment.  Our COI policies and procedures are within these same documents, but they are clearly spelled out and not interwoven.

COI & COC Policy

COI & COC Procedure

 

Massachusetts Institute of Technology

MIT has three related policies that apply to faculty:  full time service, conflict of interest and outside professional activities.  We also have a financial conflicts of interest policy.

4.3 Full Time Service

4.4 Conflict of Interest

4.5 Outside Professional Activities

Financial Conflicts of Interest

 

University of Minnesota

Outside Consulting and Other Commitments Policy

We also have a COI Policy.  The link is included in the outside consulting and conflict of commitment policy.

 

University of Nebraska

Policy Link (COC policy starts on page RP-96)

The policy is combined with a broad COI policy

This policy is a Board of Regent’s policy and applies to all 4 University of Nebraska campuses. Each campus also has their own policies that more specifically address areas such as FCOI in research etc.

 

University of Notre Dame

Notre Dame policy web site

Look for the name Conflict of Commitment in the list of all ND policies, click on the link and a pdf will download.  The COC policy applies only to faculty.

 

Northeastern University

Northeastern has separate policies for conflicts of commitment.

Policy on Conflict of Interest and Commitment

Financial Conflict of Interest Related to Research

 

Northwestern University

Our policy is a combined policy on conflict of interest and conflict of commitment and applies to all university faculty and staff but is separate from the research conflict of interest policy. 

 

University of Oklahoma

Conflict of Interest Policy

The policy covers conflicts of commitment (see sec. 2(D)) defined as commitments of time and energy.  "Commitment" is covered by the general definitional language in sec. 2.  Otherwise, unpaid service on nonprofit and scholarly boards is specifically permitted in sec. 2.I(3).

 

University of Oregon

Conflict of Commitment Policy Page

The policy is combined with our COI policy.  This policy was constrained in many ways by Oregon ethics laws, ORS 352 and ORS 244.

 

Purdue University - System-wide policies

Conflicts of Commitment and Reportable Outside Activities

Individual Financial Conflicts of Interest (Our COI and COC polices are separate)

Institutional Financial Conflicts of Interest

These policies apply to Purdue University, system-wide (main campus in West Lafayette and two regional campuses, Northwest and Fort Wayne).

 

University of Rochester

The link to our Faculty Policy on Conflict of Commitment and Interest can be found here.  COC is discussed on page 4 and is applicable University-wide.

The UR’s Faculty Handbook speaks specifically to limitations on consulting (pages 45 and 46).  This is also applicable University-wide, although the School of Medicine and Dentistry has specific guidance that speaks to physician responsibilities/limitations under the School’s faculty compensation plan.

 

Rutgers University

The University of Medicine and Dentistry of New Jersey merged with Rutgers to form the Rutgers Biomedical and Health Sciences back in 2013.  Some policies continue in effect for “Legacy UMDNJ” personnel.

Please find the links to policy addressing conflict of commitment:

Go to the Rutgers/Legacy UMDNJ policy site, look for these policies by number and a pdf will download: https://policies.rutgers.edu/

1) Policy 60.5.8 – Conflicts of Interest- Faculty: Professional Activities Outside the University and Outside Employment for Academic Personnel (Rutgers)

2)  Policy 60.9.21 – Outside Employment (Legacy UMDNJ) – for Rutgers Biomedical and Health Science (includes New Jersey Medical School, Robert Wood Johnson Medical School, School of Nursing, Rutgers School of Dental Medicine, School of Health Professions, School of Public Health, Cancer Institute of NJ, and Graduate School of Biomedical Sciences).

3) Policy 90.2.5 – Investigator Conflict of Interest (covers financial conflict of interest for both legacy RU and legacy UMDNJ)

4)  Policy 60.3.2 – Outside Work for Non-Academic Employees (Rutgers)

 

University of Southern California

Our policy covers conflicts of commitment in Section 6.  The policy also covers personal conflicts (e.g. hiring relatives) and business conflicts (e.g. purchasing conflicts).

 

University of Texas at Arlington

COI, COC, Outside Activities Policies

General COI policy is embedded in the policy above, we have a separate COI for Research Policy

 

Virginia Polytechnic Institute and State University

Individual Conflicts of Interest and Commitment