Conflict of Interest
Understanding and managing conflicts of interest effectively helps ensure your research meets ethical and professional standards.
Objectivity is at the core of research integrity
The University of Mississippi is committed to upholding the highest standards of integrity and objectivity in research. Ensuring that personal, financial, or other interests do not interfere with scholarly activities is essential for maintaining public trust, advancing knowledge, and fostering ethical research practices. By proactively identifying and addressing potential conflicts of interest, we aim to create an environment where research remains unbiased and its outcomes are credible and impactful.
The university has a responsible to manage any real or perceived conflict of interest arising from an investigator’s financial interest(s). We require that Investigators disclose financial interests that may present a real or perceived conflict of interest in relationship with their Institutional Responsibilities; and then, manage or eliminate those conflicts.
This policy applies to all sponsored projects: research, educational, and service. The disclosure of a financial interest that creates a real or perceived conflict of interest will not delay proposal submissions.
What is a significant financial interest?
Significant financial interests are financial interests, received by an Investigator, and/or their spouse or dependent children, in the past 12 months, consisting of one or more of the following that is related to Institutional Responsibilities:
- Equity interest in a domestic or foreign publicly traded company of 0-1.99% with aggregate income totaling greater than $5,000;
- Equity interest in a domestic or foreign publicly traded company of 2-9.99% with aggregate income totaling greater than $1,000;
- Equity interest in a domestic or foreign publicly traded company of 10% or greater;
- Any equity interest in a domestic or foreign private company (including start-ups);
- $5,000 or more in salary, consulting fees, advisory board fees, honoraria, gifts, “in kind” compensation, or any other remuneration from a domestic or foreign outside entity;
- An appointment to serve in a fiduciary role (director, officer, partner, trustee, or any position of management) for a domestic or foreign outside company, whether or not remuneration is received;
- Commercialization proceeds, such as licensing fees and royalties, from intellectual property (patents and copyrights);
- Any travel sponsored or reimbursed by a domestic or foreign outside entity;
- Any other compensation whose value could be affected by the outcome of research conducted at UM.
Excluded Financial Interests
- Salary or other remuneration paid by UM to you if you are currently employed or otherwise appointed by UM;
- Income from investment vehicles, such as mutual funds and retirement accounts, as long as you do not directly control the investment decisions made in these vehicles;
- Income from seminars, lectures, or teaching engagements sponsored by a U.S. federal, state, or local government agency, an Institution of higher education as defined in 20 U.S.C. 1001(a), an academic teaching hospital, a medical center, or a research institute that is affiliated with an institution of higher education;
- Income from service on advisory committees or review panels for a U.S. federal, state, or local government agency, or an Institution of higher education as defined at 20 U.S.C. 1001(a), an academic teaching hospital, a medical center, or a research institute that is affiliated with an institution of higher education.
Disclosure process
The UM Objectivity in Research Policy requires that Investigators disclose any significant financial interest are related to institutional responsibilities (i.e., teaching, research, administrative, or clinical duties). Investigator is defined in the policy as faculty, staff or students serving as Project Directors, Principal Investigators, and any member of the research team who is responsible for the design, conduct or reporting of externally sponsored research, including collaborators, consultants, subrecipients, contractors, and consortium participants. External sponsor means any granting agency outside the University, including both governmental and non-governmental sponsors.
1. Significant Financial Interests - financial interests, received by an Investigator, and/or their spouse or dependent children, in the past 12 months, consisting of one or more of the following that is related to Institutional Responsibilities.
2. Participation in a Foreign Government Talent Recruitment Program
A "Foreign Government Talent Recruitment Program" is a program sponsored by some foreign governments or affiliates with distinguishing features that generally include compensation and recruitment. Some examples can be found here.
3. Other Support
"Other Support" includes all outside resources (from foreign and domestic entities) directly supporting your research endeavors, regardless of whether or not they have monetary value. This includes (but is not limited to):
- Titled academic, professional, or institutional appointments whether or not remuneration is received, and whether full-time, part-time, or voluntary (including adjunct, visiting, or honorary).
- Research resources such as personnel, lab space, scientific materials, or high-value materials that are not freely available (e.g., biologics, chemical, model systems, technology, etc.).
All Investigators must disclose Significant Financial Interests to the Director of Research Integrity and Compliance at least annually, but no later than the following:
- Prior to first submission of a proposal.
- Prior to participating in an active, funded research project.
- Within thirty (30) days of acquiring any new Significant Financial Interest(s).
Disclosures should be made through the Qualtrics survey found here. If you have difficulty accessing the survey or have additional entities to report, a fillable form is available.
The Assistant Vice Chancellor of Research Integrity, Security, and Compliance will conduct a preliminary review of all Significant Financial Interest disclosures 1) to determine if Investigators’ disclosure information is sufficiently complete for review or whether the Investigator must provide additional information or clarification and 2) to make an initial assessment on the impact of a given Significant Financial Interest on the Research and either determine the Significant Financial Interest does not represent a real or perceived conflict or refer the matter to the Conflict of Interest Committee (COIC) for review and management.
To the extent permitted by law, including the Mississippi Public Records Act, all records of financial interest submitted by an Investigator shall be made available only to the Conflict of Interest Committee and to others on a “need to know” basis with clear understanding of the confidentiality of the information. Records will be destroyed once the record retention period expires.
As required by federal regulations at 42 CFR 50.605(b) ORED shall send report a Financial Conflict of Interest (any Significant Financial Interest that reasonably could or appear to significantly affect the design, conduct, or reporting of research)to any funding agency that has adopted PHS regulations, including the following:
- US Public Health Service Agencies including:
- NIH
- CDC
- HRSA
- FDA
- AACF
- AHRQ
- ATSDR
- IHS
- SAMHSA
- Non-PHS Agencies (subject to change, must be verified in award terms and conditions) including:
- Alliance for Lupus Research
- Alpha-1 Foundation
- Alzheimer's Drug Discovery Foundation
- American Asthma Foundation
- American Heart Association
- American Cancer Society
- American Lung Association
- Arthritis Foundation
- CurePSP
- Johnson & Johnson
- Lupus Foundation of America
- PCORI
- Susan G. Komen Foundation
- Juvenile Diabetes Research Foundation
- Federal sponsors with regulations similar to PHS or that follow a component of PHS regulations:
- Department of Energy
- National Aeronautics and Space Administration (NASA)
Sample disclosure statements
- (Name) (has financial and/or business interests in) (is a consultant to) (receives funding from) a company that may be affected by the research reported in the enclosed paper. S/He has disclosed those interests fully to the University of Mississippi, and has in place an approved plan for managing any potential conflicts arising from (that involvement).
This research is sponsored by (company A) and may lead to the development of products which may be licensed to (company B), in which (professor name) has a business and/or financial interest. S/He has disclosed those interests fully to the University of Mississippi, and has in place an approved plan for managing any potential conflicts arising from this arrangement.
For your information, I serve as (a consultant to) (a board member of) (an executive officer of) COMPANYNAME. I also receive research grant funding from (company name) investigating (briefly describe the research area). This relationship has been identified as having the potential to create a conflict of interest with my responsibilities as a faculty member. I have fully disclosed these interests to the University of Mississippi, and I have in place an approved plan for managing any potential conflicts arising from this involvement.
I understand that your work on the project, (insert project name), should be for academic reasons to further your studies and your professional career endeavors. If at any time you have any concerns about whether your work is inappropriately focused toward my outside relationship(s), or that your ability to publish has been impeded in any way, I encourage you to contact the Department Chair or (alternative advocate for the student) (include names and phone numbers, if not evident).
I look forward to continuing to serve as your advisor and you can continue to count on my utmost support of your work.
Regulations
For more details on regulations guiding conflict of interest management, explore the federal regulations at 42 CFR 50.605(a)(3)(iii), Mississippi Conflict of Interest Statute and the Mississippi University Research Authority Act (MURA).