Conflict of Interest

Frequently Asked Questions

Frequently Asked (Policy) Questions
  1. What is a conflict of interest?

    A conflict of interest is a situation in which the potential exists for the personal financial interests of a University employee to impair his/her judgment in the execution of his/her University responsibilities. University policy limits conflict of interest to financial interests.


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  2. What is the threshold for a conflict to exist?

    The three major thresholds are (1) income of $10,000 or more/year from a single business entity that is sponsoring the research or whose business is substantially related to the subject of the research; (2) equity interests greater than $10,000 and greater than 5% in such a business entity; and (3) holding the position of officer, director, agent or employee of such a business entity.

    Anything below those thresholds does not have to be reported.


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  3. Who determines if I have a conflict of interest?

    The University of Utah Conflict of Interest Committee, as designated in PPM 2- 30.


  4. What happens if I do have a conflict of interest?

    The Conflict of Interest Committee will work with you to design a way to manage, reduce or eliminate the conflict (a “management plan”). The goal of a management plan is to allow you to do your University work while ensuring that your personal financial interests do not negatively affect that work.


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  5. Who gets to see the information I provide in my disclosure?

    The information provided in a disclosure is confidential and is only used for the purposes of administering the policy by the Conflict of Interest Committee.


  6. What education and training resources are available to assist faculty and staff?

    A short program entitled “Conflicts of Interest in University Academic Research” is available for presentation at faculty meetings and department forums. The Research Administration Training Series
    ( www.education.research.utah.edu ) offers several classes and programs designed to ensure compliance with national and local regulations. You may also contact the member of the Conflict of Interest Committee most closely associated with your college or department at any time to discuss policies in greater detail. For more information please contact Tony Onofrietti, Director of Research Education, at 585-3492 or tony.onofrietti@hsc.utah.edu.


Frequently Asked (Procedure) Questions
  1. When do I have to make a disclosure?

    Procurement/purchasing: any time you request signatory authority on a University account you will be asked if you have a conflict. If so, you must fill out a disclosure form.

    Research: (1) submission of a new grant/contract/project to the Office of Sponsored Projects (OSP) OR (2) submission of a new protocol to the Institutional Review Board (IRB) requires submission of a disclosure.


  2. Why do I have to fill out a separate disclosure for every project?

    The University of Utah Conflict of Interest policy is project based. The potential for conflicts of interest arise when there is both sponsored funding for a project and an investigator who has a related significant financial or other interest. One project might involve a conflict of interest because an investigator has an investment in the funding source, while another project - for the same investigator - might have no conflict if the funding source were different. Thus, the determination of the existence of a conflict is based on the convergence of two factors - the project’s funding and the investigator's financial interests.


  3. What does the disclosure ask?

    1. Procurement:
      1. the name of the business entity that creates the conflict
      2. what is your relationship to the business entity

    2. Research:
      1. the name of the project
      2. the name of the PI (if not you)
      3. the funding source
      4. the anticipated funding date
      5. whether or not the project is an SBIR/STTR Phase I
      6. whether or not the project involves human subjects
      7. whether or not you or a member of your family have a significant financial interest in a business entity that is a sponsor of the project OR whose business is substantially related to the project

      IF your answer to vii is yes, you will be asked for more information about the business entity and your relationship to it, and to suggest a plan to manage the potential conflict of interest.

  4. Do I have to make a disclosure if I received less than $10,000 from a business entity related to the project?

    YES, you still have to make a disclosure, but you would answer NO to the question about whether or not you have a “significant” financial interest in that business entity. Your disclosure shows that you do not have a conflict of interest as defined by University policy.


  5. How do I make a disclosure?

    All conflict of interest disclosures are filed through the Electronic Research Integrity and Compliance Administration (ERICA) system. Follow this link to login to ERICA: https://erica.research.utah.edu/erica. .