Policies and Guidelines

Emory University Policies on Financial Conflicts of Interest in Research and Conflicts of Commitment

Emory Policy 7.7 for Investigators Holding a Financial Interest in Research

Requirements
  • All Investigators and individuals involved in the design, conduct, and reporting of research are required to disclose Significant Financial Interests (SFI) within 30 days of hire, annually, and within 30 days of receiving a new SFI. 
Policy Text

Emory Policy 7.38 Conflict of Commitment for Faculty, Postdoctoral Fellows or Trainees, and Research Staff

Requirements
  • Faculty, Postdoctoral Fellows or Trainees, and Research Staff must disclose and obtain prior approval to participate in paid or unpaid Professional Activities as defined in the Policy. 
Policy Text

Emory University Faculty Handbook 13.3.A: POLICY REGARDING TEACHING, RESEARCH, AND OTHER SERVICE OUTSIDE THE FACULTY MEMBER'S SCHOOL AT EMORY OR OTHER INSTITUTIONS 

Requirements
  • Faculty must disclose and obtain prior approval to participate in teaching, research, or service as required by the Faculty Handbook. 
Policy Text

Emory University Policy 7.24: Institutional Financial Interests Involving Human Subject Research 

Requirements
  • Emory must identify and manage institutional conflicts of interest.
Policy Text
Note: See each policy for exemptions.

Definitions

Compensation

Refers to anything of monetary value including, but limited to salary, consulting fees, honoraria, or other payments for services, of any type, including speaking, teaching, and educational engagements, as well as gifts to Investigators.

Conflict of Commitment (COC)

Refers to situations where an individual's intellectual energy, time, or effort to external activities outside interferes with their responsibilities to Emory University. 

Conflict of Interest (COI)

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 COI depends on the situation and not on the actions or character of an individual investigator.

Conflict of Interest and Conflict of Commitment (COI/COC) Committee

Refers to Emory's institutional committee for evaluating potential COIs and COCs

Equity Interest

Refers to stocks, stock options, or other ownership interests.

Financial Conflict of Interest in Research

Refers to the institutional determination that an individual's Significant Financial Interest could significantly and directly affect the design, conduct, or reporting of Research.

Investigator

Refers to Project Directors, Principal Investigators, members of the research team identified as senior/key personnel on the grant or contract application, progress report, or any other report, and individuals identified by the Principal Investigator or Project Director who are responsible for and have substantial independent decision making in respect to the design, conduct or reporting of the research, such as Collaborators or Consultants named on the grant.

Management Plan

A document that outlines steps to actively reduce, mitigate, or eliminate actual, potential, or perceived conflict of interest held by an employee

Postdoctoral Fellows or Trainees

Refers to individuals who have recently been granted degrees of PhD, MD, or the equivalent terminal degree, who are involved in continuing postgraduate education or training in conducting research.

Professional Activities

Refers to activities conducted on behalf of another institution that are based on the expertise and knowledge of a postdoctoral fellow or trainee or research staff member regardless of whether compensation is received.

Research

Refers to systematic investigation, study or experiment designed to develop or contribute to generalizable knowledge, including behavioral and social-sciences research. 

Regular Faculty

Refers to faculty who maintain continuous employment lasting more than one year as delineated by Human Resources (as opposed to temporary faculty who are those with a short-term assignment lasting less than one year or for a budgeted assignment).

Research Staff

Refers to full-time and part-time employees including staff scientists who:

  • Contribute intellectually to research; or
  • Design studies, collect data, conduct experiments, conduct analyses, complete reporting or dissemination activities; or
  • Will receive authorship or formal attribution on resulting publication(s) or scholarly products; or
  • Otherwise support the research infrastructure in a way that could influence the outcome of the research.

Significant Financial Interests (SFI)

Refers to financial interests held individually by an investigator, their spouse or domestic partner, and dependent children that when added together meet the following thresholds:

  • Compensation or honoraria > $5,000 from an entity within a 12 month period
  • Ownership interests valued > $5,000 in a publicly traded entity
  • Any ownership interests in a privately held entity (e.g., start-up companies, LLCs)
  • Any intellectual property ownership, licensing fees, or royalties
  • Management positions in a non-Emory entity (e.g., director, officer, trustee, management employee) held within the last 12 months
  • Sponsored travel over $5,000 within a 12-month period (except from Emory, U.S. government, U.S. higher ed, U.S. academic medical centers)

School Policies

School of Medicine

School of Medicine Industry and Other External Professional Relationships

Other Policies

NIH Conflict of Interest Policies

Guidelines for determining a Financial Conflict of Interest (FCOI)

TBD