Application of the Conflict of Interest Policy in Research
In addition to the Board of Regents Individual Conflicts of Interest Policy, all employees participating in research must meet additional disclosure and training requirements.
Training for Researchers
OUHSC Financial Conflict of Interest Training Module
The above training is required every four (4) years by all researchers internal and external to OUHSC.
*Note*: This training is for employees involved in research at OUHSC. This training is supplemental to the COI training required by all OUHSC employees.
What research is covered?
- All federally funded research
- All industry-sponsored research
- Research sponsored by foundations or other organizations with COI terms and conditions
- All research involving human participants and submitted to the IRB, regardless of funding source
- See the list of Sponsors with COI Requirements for a list of foundations known to have COI requirements.
Significant Financial Interest and PHS Policy
- Federal regulations and the PHS FCOI Policy require disclosure of Significant Financial interests on an annual basis and when a new relationship or activity arises. The required forms are found here.
- Significant Financial Interests (SFIs) are defined as:
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Nature of SFI
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Threshold
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Excluded (Do Not Disclose)
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Compensation and/or other payments for service
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Exceeds $5,000, when aggregated
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Annual Compensation received is less than $5,000, as well as any compensation received for lectures, seminars, teaching engagements, or service on advisory committees or review panels relating to federal, state, or local government agencies, an institution of higher education as defined in 20 U.S.C. 1001(a), an academic teaching hospital, a medical center, or a research institute that is affiliated with an institution of higher education, and compensation received from OUHSC funds
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Equity interests in a publicly-traded entity
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Exceeds $5,000 when aggregated
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Interests in any single entity valued at less than $5,000 as well as interests in any entity through personal retirement accounts and mutual funds
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Equity interests in a non-publicly-traded entity
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0 / Any
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Interests in any entity through personal retirement accounts and mutual funds
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Intellectual property rights and interests upon receipt of income related to such rights and interests
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Exceeds $5,000
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Royalties received from OUHSC funds, and unlicensed intellectual property that does not generate income
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Sponsored or reimbursed travel
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Exceeds $5,000
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Travel administered through OUHSC funds, and travel reimbursed or sponsored by a federal, state, or local government agency, an institution of higher education as defined in 20 U.S.C. 1001(a), an academic teaching hospital, a medical center, or a research institute that is affiliated with an Institution of higher education.
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*Note that while these are the definitions required by regulations and the OUHSC Board of Regents policy, the sponsor, your unit, or your department may require more stringent disclosure thresholds.