Institutional Conflict of Interest (ICOI)

An Institutional Conflict of Interest (ICOI)/Research Institutional Conflict of Interest (ICOI) is defined as a situation in which an Institutional Significant Financial Interest (SFI) could significantly and directly affect or reasonably appear to affect the institutional processes for the design, conduct, reporting, review, or oversight of research. 

ICOI represents financial or other situations in which the University, as an institution, has an outside interest (e.g., equity in a company doing business with the University) that could affect the design, conduct, reporting, review, or oversight of research conducted by its employees or students.  

Emory policy 7.24, Research Institutional Conflicts of Interests, safeguards Research's objectivity, integrity, and credibility by ensuring that the financial interests of Emory or its Institutional Leaders do not affect Research's design, conduct, reporting, review, or oversight. This policy defines the standards and procedures that Emory University follows to identify and manage or eliminate Research Institutional Conflicts of Interest. 

Institutional Financial Interests can be created by gifts, payments, royalty income, or other financial benefits provided to the University from for-profit entities or equity interest held by the University in the entities.   

Examples of Institutional Financial Interests include: 

  • Payments resulting from the transfer (licensing) of technology created at the University to an entity, including royalties, milestone payments, and other licensing fees; 
  • Equity in (i.e., ownership of) a company (publicly or non-publicly traded) resulting from the transfer of university technology or from direct investment; 
  • Gifts, including gifts-in-kind of goods or services, from a potential sponsor (i.e., a commercial company), from a philanthropic unit of the sponsor, or an individual affiliated with a sponsor; and 
  • Covered Official relationships where an institutional official receives payments, honoraria, royalties, equity, options and warrants, company positions (e.g., board directorships and management), or gifts. 

A potential ICOI situation arises when the company sponsors research at the university or manufactures products to be studied or tested at Emory University or under its auspices. 

The University takes a proactive approach to identifying, disclosing, and reviewing its financial interests. This is not just a task but a commitment to prevent or manage institutional conflicts of interest that may affect (or reasonably appear to affect) institutional processes for research design, conduct, reporting, review, or oversight. Our commitment to ethical research practices is unwavering, and this proactive approach is a testament to that.   

Research ICOI Committee

The Research Institutional Conflict of Interest Committee (Research COI Committee) is an ad hoc committee called by the Research ICOI Official/VPRA or designee. This committee is responsible for reviewing institutional SFIs related to research, determining research ICOIs, managing or eliminating research ICOIs, monitoring compliance with management plans, and performing other tasks as appropriate. The Research ICOI Committee's role is pivotal in ensuring the integrity and credibility of our research.

ICOI FAQ

The Research ICOI Committee's responsibilities include, but are not limited to:

  • Formulating standards and procedures to identify ICOIs and develop management plans;
  • Establishing compelling circumstance criteria and a risk matrix for evaluating ICOIs related to human subject Research
  • Convening as a committee to evaluate complex cases, as determined by the ICOIC;
  • Identifying and developing appropriate management of ICOIs;
  • Overseeing the development of education for covered individuals;
  • Developing guidelines and procedures for specific categories of ICOI that present minimal risk to the integrity of the Research and no risk for human research participants and that can be handled administratively with pre-defined

Management strategies for identified institutional conflicts of interest may include, but are not limited to: 

  • Permitting the research to proceed, subject to a plan for managing the ICOI and any personal conflicts of interest (COI); 
  • Permitting the research to proceed, with divestiture of the financial interests of the University and individual investigators or 
  • Prohibiting the research from taking place at the University. 

Conflicts of Interest (COI) represent financial or other situations where an individual has an outside interest (e.g., equity in a company, intellectual property, consultant activity with a company) that could affect the design, conduct, or reporting of their research—also referred to as personal or individual COI. 

Institutional conflicts of interest (ICOI) represent financial or other situations in which the University, as an institution, has an outside interest (e.g., equity in a company doing business with the University) that could affect the design, conduct, reporting, review, or oversight of research conducted by its employees or students. 

Organizational conflicts of interest (OCI) represent situations where an individual's service or work on behalf of a U.S. government agency or other funding sponsor may provide the University, as an institution, an unfair competitive advantage when other University members apply for a funding opportunity with that agency or sponsor.