Research Conflicts of Interest (RCOI) are common in the modern research university. UT and leading research institutions actively encourage researchers to translate knowledge they create through their research, scholarship, and creative work to the private and public sectors for the public good. Researchers are often rewarded by these outside organizations for their efforts, including through professional appointments, consulting fees, honoraria, travel support, and the sharing of royalties generated from the commercialization of their work, among other things. In many cases, these outside interests may create research conflicts of interest that must be managed to ensure the integrity of UT’s research enterprise, including researcher reputations, and to meet sponsor and university requirements.
DRIA staff work with UT faculty, staff, students, and postdoctoral scholars and fellows to identify and manage actual and perceived conflicts of interest.
Note: ORIED recommends taking steps to prepare for changes to the Outside Interest Disclosure Process. These recommendations are especially critical if you are part of a proposal team with a deadline in early 2025.
Questions? Contact Scott Canner, Research Conflict of Interest Compliance Officer, at scanner2@utk.edu. For non-research COI questions, contact Jay Bailey at vtaylor@utk.edu or see the Division of Finance & Administration COI website.
*For more information about conflicts of commitment, see Conflicts of Commitment.
The Research Conflict of Interest process relies upon the Outside Interest Disclosure (OID) process outlined in UT Policy GE0002.
- Employees submit OID forms through the IRIS Web Portal. Employees should sign in with their NetID and password and select the Employee Self-Service tab. Under the Personal Information area, choose the Outside Interest Disclosure link and follow the instructions on the screen. A brief video is available to explain the form.
- Non-employee researchers (for example, consultants) should complete the fillable pdf form, available here. Once approved by the Principal Investigator, the form should be submitted to Scott Canner at scanner2@utk.edu.
Who should disclose? As outlined in the GE0002 Guidance Document: DO I NEED TO DISCLOSE? , almost all employees – and all researchers – are required to complete OID forms. This includes faculty (even if part-time or adjunct), staff, student researchers, postdoctoral scholars and fellows, and visiting researchers who answer Yes to the question in the Guidance Document.
What should be disclosed?
Researchers must disclose any outside activity or situation that could cause a potential, real, or perceived conflict of interest or commitment. OID forms guide researchers through the items to disclose, which include consulting work, gifts, outside affiliations, other academic appointments and courtesy appointments, board memberships, equity interests over $5,000 or 5% ownership, foreign sponsored travel not reported in UT’s travel system, etc. International appointments and relationships MUST be disclosed, see Collaboration & International Engagements for more guidance.
Some activities do NOT need to be reported on OID forms, including UTRF royalties, joint UT-Oak Ridge National Laboratory appointments, and funding received by UT to support the researcher’s work. Additional details on what to disclose – and not to disclose – is provided in GE0002 Guidance Document: WHAT TO DISCLOSE.
Researchers should answer “Yes” to the question “Are you a project director, principal investigator (PI), co-PI, key personnel member, or otherwise responsible for the design, conduct, or reporting of research, or proposals for research funding?” on the OID Form, even when applying for first-time funding. This will ensure the form routes through the disclosure review system properly.
When completing an OID form, researchers should include notes and attachments to explain outside interests. Examples of helpful attachments include: 1) outside agreements and 2) emails documenting discussions with supervisors. This will expedite review of the OID Form and ensure the outside interests disclosed meet any necessary requirements.
See Guidance for Researcher’s Outside Activities and Foreign Talent Recruitment Programs for more information.
When do researchers need to disclose? Researchers must 1) disclose their outside interests within 30 days of employment, 2) report new outside interests within 30 days of their occurrence, and 3) report all ongoing outside interests in the university’s annual disclosure process. In addition, if a researcher takes a new UT position, a new OID form must be submitted within 30 days.
Please note – If a conflict of interest is not identified or managed in a timely manner, a retrospective review may be required. Examples of situations necessitating such a review include, but are not limited to:
- The Investigator not disclosing a significant financial interest as determined by the University to constitute a Financial Conflict of Interest.
- The University not reviewing or managing such a Financial Conflict of Interest.
- The Investigator not complying with a conflict of interest management plan.
NIH policy requires a retrospective review within 120 days (Section I of NIH’s FAQs).
Researchers must disclose outside activities prior to commencing a sponsored project, regardless of funding source. For some sponsors, the University is further required to ensure disclosures are up-to-date prior to submitting proposals and at time of award. The University cannot release any project or research funds until review of the relevant OID Forms has been completed.
In addition to submitting OID Forms, researchers must meet sponsor requirements to disclose affiliations and potential conflicts of interest in proposals, awards, and progress reports. Many federal sponsors require the inclusion of an up-to-date biosketch for all principal investigators and senior personnel participating in projects proposed for funding. Contact the UT Division of Research Administration or UTIA Office of Sponsored Programs with questions.
Questions or concerns related to disclosing research outside interests? Contact Scott Canner at scanner2@utk.edu or Jane Burns at janeburns@utk.edu.
Employees should discuss outside interests and affiliations with their supervisors before entering into such arrangements. Supervisors reviewing OID forms should ensure all known outside interests are disclosed, review disclosed interests with the employee, discuss any unanswered questions or open issues concerning an outside interest, and evaluate if an actual or perceived conflict may exist.
Supervisors should consider whether the disclosures in the OID form match with what they know about the individual. The following questions might be considered:
- Is the researcher involved in a start-up company?
- Are there any inconsistencies from what you have come expect as typical travel for the employee?
- Does the researcher perform services for an outside company?
- Is the researcher affiliated with other organizations?
- Are the activities disclosed likely to interfere with their UT responsibilities?
- Has outside work been approved that may create a conflict of commitment (see Faculty Handbook for guidance) or problems with meeting effort reporting requirements?
- Does the employee supervise a relative?
Supervisors should:
- Review time commitments based on appointment type and time of year.
- Attach relevant documents, such as forms or e-mails approving outside activities, to the OID Form.
- Include comments to help subsequent reviewers.
- Lead by example.
Specific questions a supervisor might ask a researcher relevant to the disclosures made may include:
- Why was a known activity not disclosed?
- How does a disclosure relate to procurement or research activities (funded or unfunded)?
- What are the benefits of the outside interest to the researcher and/or the University?
- How long has the outside interest existed and was advance approval obtained and documented?
- Is a contract attached? If the contract is not in English, is a translated version included?
- Are UT resources used as a result of the outside interest? If yes, is a facility use agreement in place and attached?
- What are the IP rights associated with this affiliation/disclosure?
- Are students involved and how does it impact them?
- How is the researcher managing their time, since the aggregate of external activities may be extensive? Is it consistent with the researcher’s effort certification?
If the researcher has not attached agreements or relevant approvals, the supervisor can attach them during review.
Supervisors should indicate Yes if their opinion is that an actual, perceived, or potential conflict may exist and provide an explanation of their reasoning in the text box to expedite subsequent review.
Research conflicts of interest are common in the modern research university and most can be managed. However, full disclosure of outside interests is critical to the integrity of the research enterprise.
When an outside interest creates a conflict of interest – or appears to create a conflict – the RCOI committee will review the circumstances of the outside interest and determine if a Management Plan is necessary to ensure research integrity.
RCOI Management Plans are designed to create transparency and define expectations. Common mitigation measures in RCOI Management Plans include:
- Public announcements of conflicts (e.g., when presenting or publishing the research);
- Announcements of conflicts directly to participants (e.g., if involving human subjects);
- Appointment of an independent monitor capable of implementing measures to protect the design, conduct, and reporting of research against bias resulting from the conflict; and
- Modification of the research plan.
RCOI Management Plans include requirements to report periodically to the RCOI Committee. Plans are typically reviewed by the committee annually.
For assistance with a RCOI Management Plan, contact Scott Canner at scanner2@utk.edu. Click here for a sample Management Plan.
An online COI course is available at Collaborative Institutional Training Initiative (CITI) for all employees & research visitors. Public Health Service (PHS) agencies, such as the National Institutes of Health (NIH) and the Center for Disease Control (CDC), require that investigators take COI training before they work on PHS projects; training must be repeated every four years. UTK uses the CITI course as a way to meet the training requirement.
In addition, the Division of Research Integrity & Assurance offers in-person or Zoom RCOI training sessions, see Workshops & Opportunities. Personalized sessions can also be arranged by contacting. Scott Canner at scanner2@utk.edu.
The DHHS Office of Research Integrity provides online materials about RCOI.
NIH provides institutions with FCOI training resources to train Investigators about the regulation on its FCOI Training website.
When applying for or receiving external funding, researchers must familiarize themselves with new and evolving requirements relating to outside interests and disclosures.
When submitting a proposal, potential conflicts of interest should be noted by marking “Yes” in the appropriate places on the Conflict of Interest page in Cayuse. “Yes” responses should be explained in a note or with an email that is uploaded in Cayuse. Potential conflicts of interest which do not meet the questions posed should be emailed to Scott Canner, Research Conflict of Interest Officer, for review and possible addition to Cayuse.
It is the responsibility of the Principal Investigator to ensure any potential conflicts of interest related to the project are disclosed by their team members. The Principal Investigator will answer for the entire team when responding to COI questions in Cayuse.
It’s increasingly common for sponsors to require certification that all real, perceived, and potential conflicts (individual and organizational) have been disclosed. Wording and requirements vary considerably by sponsor, and they may be required in pre-proposals, proposals, and at the time of award. Typically, the Authorized Organizational Representative provides this certification on behalf of all identified research team members, and some sponsors provide sections on a certification document to list potential conflicts. Please provide the Division of Research Administration adequate time to review all proposal documents to ensure any applicable disclosures are included.
Some federal sponsors will not allow a researcher to work on projects they fund if the researcher is involved in a foreign talent recruitment program (e.g. the Department of Energy’s Directive DOE O 486.1 on Foreign Government Talent Recruitment). In some cases, the sponsor may require an attestation that researchers are not involved in a foreign talent recruitment program; in others, the sponsor may include the requirement in award terms and conditions.
Senior/Key personnel often must disclose outside interests and current, pending, and other support disclosures in the proposal. Contact the UTK Division of Research Administration or UTIA Office of Sponsored Programs with questions about proposal documents.
Small Business Innovation Research (SBIR) and Small Business Technology Transfer (STTR) proposals are submitted by small businesses and support rapid progress toward commercialization of inventions. Researchers may be key personnel in SBIR/STTR proposals and also may have interests in the small business. SBIR/STTR and other proposals involving start-up companies may result in the need for a conflict of interest Management Plans, especially as technology advances. Please contact Scott Canner at scanner2@utk.edu with questions or to develop a Management Plan.
The University COI policy was updated in April 2022, to reflect new Federal requirements and clarify process. Policy GE0002 – Conflicts of Interest & Commitment includes Guidance documents to assist employees:
Other University guidance related to COI and COC include:
Federal Policy & Guidance Links
Stay tuned for additional COI requirements and guidance, as it is developed by Federal agencies.