Conflicts of Interest in Research:
Disclosure Review Process
Understanding disclosure reviews
Once you have submitted your disclosure, the financial interests you disclosed will be reviewed by Office of Research Integrity (ORI) staff.
Types of Office of Research Integrity review
Conflict of interest disclosures fall into two categories: those without significant financial interests and those with significant financial interests. If your COI disclosure reports no significant financial interests, the InfoEd COI disclosure system immediately routes it into an “No Significant Interests” status and no ORI review occurs, under normal circumstances.
If your COI disclosure reports significant financial interests, the form is immediately submitted to the ORI staff and the status of “Received (not yet reviewed)” is displayed on your InfoEd dashboard. ORI staff will review the disclosure to verify that it is complete and prepare a summary for further review. If additional information is required, you will receive an email.
Designated Official and Conflict of Interest Committee Management (CIMC) review
ORI will prepare a summary of each disclosure with significant financial interests and evaluate for the relatedness to the research activities of the disclosing individual. The summary will be presented to the Designated Official (VP of Research and Economic Development). The Designated Official may determine that the disclosure financial interest does not constitute a COI or may request that CIMC review. For those that are sent to CIMC, CIMC will review the summary, the research activity of the disclosing individual, and other pertinent information to determine what action is necessary or what additional facts may be needed. Depending on the nature of the significant financial interest, the CIMC may recommend that the COI be managed, reduced, or eliminated. The CIMC also may determine that no action is necessary or request that a best practices memorandum be put into place.
Compliance review
A current and complete COI disclosure must be verified by ORI before any type of research or sponsored program activity may begin. If you have not filed a current COI disclosure, you will be contacted to do so immediately. If you’ve filed a disclosure but it requires CIMC review, the ORI will expedite review at the next committee meeting. Failure to have a current disclosure on file or to provide additional information requested by ORI may result in a delay of study approval and/or release of research funds.
Procedures for Rhode Island Public Private Partnership Act
The University of Rhode Island is committed, within the laws of the State, to assist faculty and staff members in their pursuit of education, research and service through their university or college duties. URI also recognizes that employees involved in research and development activities may also involve themselves in public private partnerships or have some other relationship with business or other entities that require an exemption from the Rhode Island Ethics Code under the provisions of the Public Private Partnership Act.
Given the nature of such partnerships and relationships, there exists a real potential for actual or perceived conflicts of interests between the employee’s obligations to the university or colleges and the relationships attendant to his or her research or development activity. Whenever the question or appearance of such of such a conflict exists, the employee is required to disclose the potential conflict and, where necessary, a request for appropriate exemption shall be made in accordance with the law.
Some examples of activities that would be in conflict with the employment duties of an Employee and are therefore in violation of the Rhode Island Code of Ethics include:
- Disclosure of confidential information acquired by an Employee in the course of and by reason of their official duties or employment or use of any such information for the purpose of pecuniary gain (RIGL §36-14-5(b)(c)).
- Using one’s employment by the University to obtain financial gain, other than that provided by law, for themselves or any person within their Family, any Business Associate of the Employee, or any Business or entity by which the person is employed or which the person represents (RIGL §36-14-5(d));
- Acceptance of a position or other employment that will impair the Employee’s independent judgment;
- Acceptance of an honorarium, fee, or other compensation for any activity that directly relates to the Employee’s duties and responsibilities unless the Employee, when engaging in and preparing for the activity, uses their own time and does not make improper use of State materials or resources;
- Soliciting political contributions from a subordinate over whom the Employee exercises supervisory responsibilities;
- Having, or a member of the Employee’s Family or their Business Associate having, a Substantial Ownership Interest in a Business or entity that is contracting with a state or municipal agency, unless the contract is awarded through an open and public bid process;
- Engaging in a financial transaction, including participating in private employment or consulting, and giving or receiving loans or monetary contributions, with a subordinate or person or Business for which, in the Employee’s official duties and responsibilities, they exercise supervisory responsibilities, unless:
- The financial transaction is in the normal course of a regular commercial business,
- The subordinate or person or Business or entity initiates the financial transaction; or
- The financial transaction involves a fundraising activity officially sponsored by the University, the University Foundation, or any government agency.
These are just a few examples of conflicts that are prohibited by the Rhode Island Code of Ethics and/or the Regulations of the Rhode Island Ethics Commission. University Employees are referred to the University’s policies on “Ethics and Conflict of Interest,” “Public-Private Partnerships in Research and Development“, the website of the Rhode Island Ethics Commission, and Rhode Island General Laws, Title 36, Chapter 14 for more detailed information.
Need help?
If you have any questions about the InfoEd COI system or process, please contact researchintergrity@etal.uri.edu.