Conflict of Interest Policy
This policy is organized into six major sections. The sections are the Preamble, Disclosure, Review, Management, and Reporting of Financial Conflicts of Interest and Other Policy Considerations.
Revised: February 2015
As an institution dedicated to excellence in research and education, Tufts University (the University) places a high value on research integrity and academic freedom. Objectivity in the conduct of research, the freedom to disseminate ideas through publication of research results, the protection of the rights and interests of research subjects, maintenance of public trust, and the ability to insure that our responsibility to our students and trainees is not compromised are critical to these institutional values. Relationships with industry and other outside entities, while important to the support and advancement of research, can present special challenges in protecting these institutional values.
In the context of conducting research, the primary interest of a researcher should be the objective conduct of the research. Coupled with this, the researcher, the University, and the public share an interest in the complete, objective and timely communication of research results. While the University expects that all of its faculty and other research staff should carry out their professional responsibilities with the highest standards of personal integrity, it is necessary to acknowledge and to avoid or manage situations where a secondary interest could reasonably be expected by others to influence decision-making.
To say that one has a conflict of interest does not necessarily mean that the individual involved acted or is expected to act inappropriately. It is the existence of the competing interests that creates the initial conflict of interest concern.
Conflict of interest can be defined as a situation in which an investigator’s external interests undermine, appear to undermine, or have the potential to undermine the investigator’s ability to perform his or her ethical, legal, or professional duties. The potential for personal gain or the existence of competing interests must not jeopardize or appear to jeopardize the integrity of the research, its design, or the interpretation or reporting of research results.
The University Policy on Conflict of Interest in Research for grants and proposals requires the disclosure of financial interests or associations with other organizations including reimbursed or sponsored travel that could directly and significantly affect the design, conduct, or reporting of the funded research.
The policy is organized into six major sections. The sections are the Preamble, Disclosure, Review, Management, and Reporting of Financial Conflicts of Interest and Other Policy Considerations.
- The Preamble
The Preamble provides the institutional official’s contact information and lays out the authority, applicability and purpose for promoting objectivity in research. Definitions are listed to clarify the meanings of conflict of interest terms and provide examples of reportable activities.
- Disclosing Significant Financial Interests (SFI) and Conflict of Interests
This section explains the process investigators follow to make their disclosures including subrecipient investigators as it relates to the project sponsor, that is, whether it’s a federal or non-federal sponsor. The section also explains the policy for failure to make a disclosure.
- Review of Conflict of Interests
The third section, explains the review process taken by the Chair of the Committee on Conflicts of Interest in Research (CCIR) when determining whether a disclosure relates to the research and if so whether there is a conflict of interest. It describes the involvement of the department chairs, deans and the Office of the Vice Provost for Research in eliminating, reducing or managing a conflict of interest.
- Management of Financial Conflict of Interests
The section provides examples of when a plan would be imposed and what a plan would entail. It also clarifies the PHS policy on public access to FCOIs that were reported to the PHS.
- Reporting of Financial Conflict of Interests
Reporting FCOIs is specific to PHS sponsors where reporting FCOIs is a federal requirement. This section explains the process and reporting requirements.
- Other Policy Considerations
The last section addresses various items related to the policy. It touches on CCIR Membership, Record Retention, Publication, Students/Trainees, Human Subjects, and Special Considerations for Faculty Start-up Companies.