THE OFFICE OF RESEARCH

NEW INVESTIGATORS: A QUICK GUIDE TO STARTING YOUR RESEARCH AT UCSF

Table of Contents

Finding, Obtaining and Managing Money - Other Topics:
| What do I need to know about fiscal responsibility? | Pre-award: How do I find and ask for funds? | Post-award: How do I manage funding awards? | How do I work with Industry?
| How do I maximize the value of and protect the intellectual property I create? |

FINDING, OBTAINING AND MANAGING MONEY

How do I minimize financial conflicts of interest?

• What is financial conflict of interest?
• Who do I contact if I have questions?
• What am I responsible for?
• How does UCSF determine if there is financial conflict of interest?
• Can I still do my research if there is a conflict of interest?
• Relevant policies and procedures

What is financial conflict of interest?

The term "conflict of interest in research" refers to situations in which financial or other personal considerations may compromise, or “have the appearance of compromising”, an investigator's professional judgment in conducting or reporting research. A conflict of interest does not imply that there is research misconduct or unethical behavior.

In fact, federal regulations, state law and University policies related to conflict of interest recognize that faculty may have financial interests in sponsors of their research and/or in entities whose business interests are closely related to their research.

However, these regulations require you, as the Principal Investigator, or as a participant in the research, to disclose any potential or actual financial conflicts of interests that you may have. These conflicts must be reviewed by the Conflict of Interest Advisory Committee prior to acceptance of research funding.

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Who do I contact if I have questions?

If you need information on disclosure policies and procedures or have questions about the financial disclosure forms, contact the COIAC Administrator at (415) 476-5566.

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What am I responsible for?

As a researcher, you are responsible for the effective management of all aspects of your research, which includes managing potential financial conflicts of interest. This can best be accomplished by:

•	Accurate financial disclosure,
•	Attention to minimizing or avoiding conflict of interest,
•	Ongoing active management of conflict of interest within your projects,
•	Assuring that your outside activities do not interfere with your faculty obligations to the University in teaching, research, and public service,
•	Assuring that no portion of time at the University is devoted to private purposes, and
•	Submitting an annual faculty report on your outside professional activities to the department chair for inclusion in your faculty record.

Note: Other participants in your research project must also disclose any financial conflicts of interest that they may have with a funding source or with a related entity. For example, when you apply for a NIH grant, you and any of the staff who have responsibility for the design, conduct or reporting of the project must submit the disclosure form for financial conflicts of interest.

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How does UCSF determine if there is a financial conflict of interest?

The Conflict of Interest Advisory Committee (COIAC) reviews all financial conflicts of interest in conjunction with sponsored research agreements (whether a contract or grant) and research gifts. The process for review is as follows:

•	You complete the appropriate Financial Disclosure forms and attach it to your funding application that you submit to the appropriate unit of the Office of Sponsored Research (OSR).
•	The OSR submits the Financial Disclosure Forms to the COIAC for its review.
•	The COIAC reviews your information for compliance with federal and State of California laws, as well as with UC and UCSF policies.
•	The COIAC then makes a recommendation to the Executive Vice Chancellor-Research:
	•	To accept the research funding or gift, or
	•	To accept with conditions the research funding or gift, or
	•	To disapprove the gift, grant or contract.

The COIAC review and recommendation must be completed before the University can accept funding. Allow enough time for the Office of Sponsored Research divisions (C&G or ICU) to review your proposal packet, and to submit your financial disclosure forms to the COIAC, and for COIAC to review the conflict. The COIAC meets on the third Thursday of each month and it requires at least two weeks to review the materials before the meeting.

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Can I still do my research if there is a conflict of interest?

Yes, with the approval of the Executive Vice Chancellor, Research (EVC) after review by the COIAC. In situations where a faculty member may have a conflict of interest in conjunction with his or her research, there are methods to manage that conflict. For example, you can disclose the conflict of interest in public lectures and publications emanating from the research.

If your research includes human subjects, you will need to disclose the conflict of interest in your protocol as well as in your informed consent documents that you submit to the CHR for their review and approval.

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Relevant policies and procedures:

There are two conflict of interest policies issued by University of California (one in 1984 and the other in 1995, revised 1997), and there is a set of conflict of interest guidelines issued by UCSF, which are set forth in full under the policy link on the COIAC website.