The document outlines proposed changes to Yale University's Conflict of Interest (COI) policy, focusing on the assessment of financial conflicts of interest (FCOI) for faculty and researchers. Key updates include revised thresholds and definitions for reporting significant financial interests (SFI), which are tailored according to the funding source (e.g., general Yale policy, Public Health Service, National Science Foundation). Generally, activities generating more than $10,000 over the past 12 months or exceeding 5% equity in publicly held corporations must be reported, with stricter thresholds (>$5,000) and additional disclosure requirements for certain federally funded research. There are specified exclusions, such as travel expenses, book royalties, and certain professional activities, though these exclusions vary by funding branch.
The policy further details factors to be considered by Yale’s COI Committee when determining the existence of an FCOI, emphasizing the nature of the SFI, its potential to bias research, and the context of the research itself—particularly in cases involving human subjects or startup companies. Special scrutiny is applied to large SFIs exceeding $100,000 and to complex entanglements between researchers and external entities. The revised policy incorporates principles related to startup involvement and addresses scenarios in which a researcher's expertise or ongoing role is essential, the research's commercialization potential, and the robustness of external oversight. Overall, these changes are designed to enhance transparency, minimize bias, and ensure the integrity of Yale's research activities.
