Conflict of Interest/Commitment (COI/COC)

Financial conflicts of interest (FCOI) in research may occur when outside financial interests compromise, or have the appearance of compromising, the professional judgment of a researcher when designing, conducting, or reporting research. FCOIs are not inherently bad and do not always lead to biased behavior.

Outside activities and financial interests that reach the significant financial interest (SFI) threshold are identified during the disclosure process and evaluated by Research Compliance to determine if they are related to the Investigator’s institutional responsibilities.

Significant Financial Interest (SFI) Thresholds

A significant financial interest (SFI) is defined as a financial interest consisting of one or more of the following interests of the investigator (and those of the investigator’s spouse and dependent children) that reasonably appear to be related to the investigator’s university responsibilities:

  • Publicly traded entity: If the value of any remuneration received from the entity in the 12 months preceding the disclosure and the value of any equity interest as of the date of disclosure, when aggregated, exceeds $5,000.

  • Non-publicly traded entity: If the value of any remuneration received from the entity in the 12 months preceding the disclosure, when aggregated exceeds $5,000, OR when the Investigator (or investigator’s spouse or dependent children) holds any equity interest.

  • Intellectual property rights and interests (e.g., patents, copyrights, trademarks): Upon receipt of income related to such rights and interests.

  • Sponsored or reimbursed travel: Travel greater than $5,000 that is paid on behalf of the investigator. (Note: Travel that is sponsored or reimbursed by a federal, state, or local government agency, or is funded through a sponsored contract or grant through the Office of Research is excluded.)

The term significant financial interest does not include the following:

  • Salary, royalties, or other remuneration paid by UNM

  • Income from seminars, lectures, or teaching engagements sponsored by a federal, state, or local government agency, an institution of higher education, an academic teaching hospital, a medical center, or a research institute that is affiliated with the university

  • Income from service on advisory committees, review panels for a federal, state, or local government agency, institution of higher education, an academic teaching hospital, medical center, or research institute affiliated with the university.

Determination of a Financial Conflict of Interest

A Financial Conflict of Interest (FCOI) is an SFI that could directly and significantly affect the design, conduct, or reporting of research. The Office of Research Compliance will escalate disclosures containing actual or potential conflicts of interest related to sponsored research to the Research Conflict of Interest Committee for review. The Research Conflict of Interest Committee will determine if a monitoring plan or other action is necessary.