Conflict of Interest / Financial Disclosure Policy Overview

Introduction

The University's Administrative Regulation on Conflict of Interest/Financial Disclosure Policy (AR II-4.0-4) requires that all investigators on sponsored projects file a Disclosure of Financial Interest form for each proposal.

Background

In response to National Science Foundation and U.S. Department of Health and Human Services initiatives, the University of Kentucky has instituted a Conflict of Interest/Financial Disclosure Policy. This policy closely mirrors the federal regulations, which became effective on October 1, 1995. The intent of the policy is to help ensure the integrity of all research, to avoid any perception that an investigator's financial interests might have either a positive or negative effect on proposed research. Investigators are defined in the Administrative Regulation as a principal investigator, co-principal investigator or any other person at the University responsible for the "design, conduct or reporting of the research."

Procedures  

Concurrent with a proposal submission, investigators must complete the disclosure form and, if applicable, disclose any "significant financial interest" as defined in the policy and relevant to the research. After completing their portion of the form, the investigator then submits the form for consideration by their appropriate university official, i.e., College Dean or Associate Dean for Research or the Research Center Director.

If the investigator has no significant financial interest, the university official will mark the form as having "no" potential conflict of interest, and should forward the Disclosure form to the Office of Sponsored Projects Administration (OSPA). This may be done either when the investigator turns in the proposal to OSPA, or later if the appropriate official is unavailable to sign the Disclosure form. By signing the Internal Approval Form accompanying each proposal, investigators attest they have read the Conflict of Interest/Disclosure of Financial Interest policy and have submitted the Disclosure form to their appropriate official.

If the investigator has a relevant significant financial interest, then the appropriate university official must determine whether a person could reasonably conclude that the interest could directly and significantly affect the design, conduct, or reporting of the proposed research. If it can, then a conflict of interest exists. The investigator and appropriate official should, if possible, derive a joint management plan to reduce, manage or eliminate the potential conflict.

If a joint management plan cannot be derived, then the investigator and university official are required to submit separate management plans, which will automatically be referred to the University's Conflict of Interest Committee.

In either case, the form and plan(s) should be sent in a sealed envelope marked "confidential" to the OSPA Conflict of Interest Administrator, who will then send the material to the Executive Vice-President for Research, or the Conflict of Interest Committee, as appropriate.

 In all cases, the Conflict of Interest Policy and its resultant procedures fall under the responsibility of the Executive Vice-President for Research, who has the final word on all decisions.

 In sum, the University's Conflict of Interest/Financial Disclosure Policy enables the University to comply with federal regulations, while helping ensure the integrity of the research performed at the University.

Learn More

Visit the Conflict of Interest section of our website to learn more about Conflict of Interest / Financial Disclosure Policy.