UCOP POLICIES

The University of California Office of the President (UCOP) issued its first “Conflict of Interest Policy,” dated April 26, 1984, and also issued the “Guidelines” for that policy on April 27, 1984, both of which became APM-028 (http://www.ucop.edu/acadadv/acadpers/apm/apm-028.pdf). Under this first policy, the President of UC directed the Chancellors of the UC campuses to develop a procedure for independent review of a principal investigator’s financial interests in a private research sponsor. Part of the review is the establishment of an Independent Substantive Review Committee (ISRC). At UCSF, the ISRC is the Chancellor’s Conflict of Interest Advisory Committee (COIAC).

In 1995, the federal government (PHS and NSF) issued regulations concerning “Objectivity in Research” (i.e., financial conflict of interest). In response to those regulations, UCOP issued a second “Conflict of Interest Policy” in October 1995 (revised 1997), which can be found at http://www.ucop.edu/research/disclosure.html.

This second policy supplements the first policy, but does not replace the first policy and guidelines.

Under these two conflict of interest policies, UCSF is required to review all financial disclosures in conjunction with research grants, contracts and gifts, and to determine whether any related financial interest is one which would reasonably appear to be directly and significantly affected by the proposed sponsored project or gift to the University. At UCSF, the COIAC reviews the financial disclosures, assesses the individual cases of financial interest, and recommends appropriate safeguards, if necessary, through management, reduction, or elimination of the interests.

For policies issued by the University of California Office of the President, including the policies referenced above, see the “Business and Finance Bulletin G-39, Conflict of Interest Policy and Compendium of Specialized University Policies, Guidelines, and Regulations Related to Conflict of Interest,” which can be found at http://www.ucop.edu/ucophome/policies/bfb/g39.html. Pages 6 through 13 of that Bulletin contain a brief summary of each policy, guideline, or regulation that is related to conflict of interest. The links to those items are contained in the table of contents on pages 1 through 5 of the Bulletin.

Updated March 2005