The requirements of the policy on Research Conflict of Interest (PP1029) apply to faculty, staff, and students responsible for the design, conduct, or reporting of research at UT Dallas that is funded by a private or public agency, or research that may appear to present a likelihood of bias. The requirements of the policy on Outside Activities (PP1102) apply to all UT Dallas employees.
General Faculty and Staff
UT Dallas faculty and staff members must disclose outside employment, board service, and other compensated activities to comply with PP1102. Approval by the employee’s school dean is required prior to engaging in such activities.
UTD researchers must complete the Conflict of Interest and Commitment (COIC) Form on an annual basis to comply with the requirements of the PP1029. Researchers must submit or have a current COIC Form on file no later than the time of application for research funding, or at the time of research protocol submission (e.g., submission to the Institutional Review Board).
Graduate students who serve as principal investigator or co-investigator for research that is supported by external funding must complete the COIC Form on an annual basis. Students acting as principal and co-investigators for research that requires approval by the UTD Institutional Review Board must complete the conflict of interest statement in the protocol application.
Disclosure of Outside Interests and Activities
Faculty and researchers must use the Conflict of Interest and Commitment Disclosure Portal provided by the Office of Research Compliance to disclose outside interests and activities in compliance with UT Dallas policy.
Faculty members and researchers must submit or update an Entity Disclosure in the COIC Disclosure Portal before engaging in a new outside activity, or within 30 days of acquiring or receiving a new outside interest. The Entity Disclosure should be completed by UT Dallas faculty and researchers who need to:
- Disclose an financial or fiduciary interest related to their research or other institutional responsibilities at UT Dallas;
- Request approval for outside employment, board service, or other activity; or,
- Disclose an conflict of interest with their institutional responsibilities at UT Dallas.
Only one Entity Disclosure is needed for each company or nonprofit in which you have an interest or activity. The Entity Disclosure allows you to disclose all interests and activities you conduct with that company or entity.
Review and Approval
Your Entity Disclosure will be reviewed by the Conflict of Interest Manager for the possibility of a conflict of interest. If you disclose an interest or activity related to your UT Dallas institutional responsibilities, you will be contacted for more information.
The Entity Disclosure will also be reviewed by your Approval Authority if you request approval for an outside activity. The President has delegated responsibility and authority for the approval of outside activities to the following offices:
- For members of the faculty: Dean
- For deans and department chairs: Provost
- For administrative and professional staff: Supervisor
Failure to disclose may delay the grant proposal process, as without an active disclosure, funding proposals may not be submitted to or accepted by the funding agency and pending awards may not be processed by the Office of Sponsored Projects. Timely disclosure is of particular importance for researchers with active or proposed projects funded by the National Institutes of Health and National Science Foundation.
UT Dallas Policies
- PHS Federal Regulations (42 CFR Part 50 Subpart F, 45 CFR Part 94)
- National Science Foundation (Proposal and Award Policies and Procedures Guide)
State of Texas Government Code
- Texas Government Code Chapter 572 – Personal Financial Disclosure, Standards of Conduct, and Conflict of Interest.
UT System Regents Rules and Systemwide Policies
- UT System Board of Regents’ Rules and Regulations: 30103 (Standards of Conduct), 30104 (Conflict of Interest), 60306 (Use of University Resources), Series 90000 (Rules for Intellectual Property)
- UT Systemwide Policy 175 (Disclosure of Significant Outside Interests and Management and Reporting of Financial Conflicts of Interest in Research)
- UT Systemwide Policy 180 (Conflicts of Interest, Conflicts of Commitment, and Outside Activities)
Conflict of Interest
A conflict of interest is a situation in which a financial interest could directly or significantly affect an individual’s performance of their institutional responsibilities on behalf of UT Dallas, including the design, conduct, or reporting of research. A conflict of interest generally involves questions of financial gain.
Conflict of Commitment
A conflict of commitment is a situation in which the time or effort that an employee devotes to an outside activity directly or significantly interferes with the employee’s fulfillment of their institutional responsibilities on behalf of UT Dallas, or when the employee uses State of Texas property without authority in connection with the employee’s outside activity. A conflict of commitment generally involves questions of time and effort.
Institutional Responsibilities are the work an individual performs for UT Dallas as part of his or her appointment or position, including research, research consultation, professional practice, teaching, educational activities, administrative duties, and committee membership. These responsibilities also may include the authority related to the management and execution of contracts and purchasing.
Financial and Fiduciary Interests
Financial and fiduciary interests held by UT Dallas researchers in an entity other than UT Dallas that are related to their institutional responsibilities require disclosure under PP1029. Such interests include:
- Compensation, travel reimbursement, or royalty income from a single entity that exceeds $5,000 in the previous 12 months.
- An equity interest that represents more than $5,000 in fair market value, more than 10% voting or participating interest, a controlling interest, or any interest (>0%) in a privately held business entity.
- A gift that represents more than $250 in value.
- A fiduciary interest in a business or non-profit entity (i.e., a position entrusted with the protection of the assets of an entity, such an executive, an officer, or director).
A financial or fiduciary interest is “related” to a researcher’s Institutional Responsibilities if the performance of their institutional responsibilities at UT Dallas appears to directly or significantly affect either their interest in an outside entity, or the interests of such an entity.
An Outside Activity occurs outside an individual’s scope of employment for UT Dallas. Approval is required prior to engaging in outside employment, board service, or other compensated activity.
The following outside activities do not require approval:
- Service on outside boards that are primarily personal in nature and are not related to the employee’s institutional responsibilities, including for organizations of the following nature: municipality; local religious congregation; neighborhood association; public, private, or parochial school; political organization; social advocacy organization; youth sports or recreation league; and affinity group such as the local orchid society.
- Activities conducted by faculty members as part of scholarly work, including:
- Serving on a federal, state, or local government agency committee, panel, or commission;
- Acting in an editorial capacity for a professional journal;
- Reviewing journal manuscripts, book manuscripts, or grant, or contract proposals;
- Attending and presenting talks at scholarly colloquia and conferences;
- Developing scholarly communications in the form of books or journal articles, reviews, movies, television productions, and similar works, even when such activities result in financial gain, consistent with intellectual property and other applicable UT System and institution policies and guidelines;
- Serving as a committee member, an officer, or board member of a professional or scholarly society, or school board; and,
- Accepting a commission for an architectural work or artistic work or performance that is considered an integral part of a faculty member’s academic portfolio.
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- Institutional Review Board (IRB)
- Institutional Animal Care and Use Committee (IACUC)
- Institutional Biosafety and Chemical Safety Committee (IBCC)
- Conflict of Interest (COI)
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- Responsible Conduct of Research (RCR)
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