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University Policy

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Research Conflicts of Interest

The Office of Research Compliance (ORC) at The University of Texas at Dallas (UTD) has provisionally implemented the policy on Conflicts of Interest in Sponsored Research to help faculty members and research investigators identify and manage situations in which their outside financial and fiduciary interests may create the possibility for a conflict of interest related to their research at UT Dallas. The policy and the accompanying procedures help researchers comply with state laws, federal regulations, and UT System rules, and address specific conflict of interest situations deemed important at UTD.

Faculty, staff and student researchers comply with the policy by completing the annual policy compliance training and the Conflict of Interest and Commitment Disclosure. The policy compliance training describes the policy terms and helps researchers determine if they have a financial or fiduciary interest related to their institutional responsibilities that needs to be disclosed. The full disclosure must be completed by all UTD investigators who are responsible for research projects supported by external funding (e.g., grants, contracts, gifts). Please visit the Disclosure Portal page for more information.

The Institutional Official has delegated responsibility and authority for initial review of research conflict of interest situations to the Office of Research Compliance, within the Office of Research, subject to oversight by a Conflict of Interest Management Plan Review Panel administered under the auspices of the Research Integrity Committee. Please visit the Research Integrity Committee page for more information.

Provisional Policy: Conflicts of Interest in Sponsored Research

Federal and UT System Requirements

The National Science Foundation (NSF) and the Public Health Service (PHS) require UT Dallas solicit disclosures of related financial interests from all persons responsible for the design, conduct, or reporting of research proposed for funding or funded by those agencies. UT Systemwide Policy 175 extends the disclosure requirement to all persons responsible for the design, conduct, or reporting of all research conducted at UT Dallas, including faculty, staff and students. The UT System requirement applies broadly to research performed at, or on behalf of, UT Dallas, without regard to the whether the research has external funding and, if externally funded, regardless of the funding source. The term “research” includes both basic research and applied research or product development.

To meet these disclosure requirements, any person responsible for the design, conduct, or reporting of research must disclose annually outside interests that are related to research they are conducting or proposing to conduct. An outside interest is related to research if the interest would reasonably appear to be affected by the research or is in an entity whose interests would reasonably appear to be affected by the research. Researchers must also disclose related outside interests that arise throughout the year within 30 days of discovering or acquiring the interest.

The high degree of professional autonomy granted to researchers carries with it the professional responsibility for disclosing an outside interest that could reasonably be viewed by others as biasing the investigator’s professional judgment. The investigator’s personal belief that the competing interest would not actually bias his or her actions should not be a factor in the investigator’s decision whether to disclose the interest under the policy. The policy supports openness and erring on the side of disclosure.

Outside Interests that Require Disclosure

As defined under federal guidelines and UT System policy, researchers are required to disclose the following outside interests that are related to their institutional responsibilities and may create the possibility for a conflict of interest:

  1. Compensation, travel reimbursement or royalty income that exceeds $5,000 in the previous 12 months.
  2. An equity interest that represents more than $5,000 in fair market value, more than 10% voting or participating interest, a controlling interest, or any interest (>0%) in a privately held business entity.
  3. A gift that represents more than $250 in value.
  4. A fiduciary interest in a business or non-profit entity.

The following outside interests do not require disclosure:

  1. salary, royalties, or other compensation researchers are paid by or through UT Dallas if the researcher is currently employed or otherwise appointed by UT Dallas, including intellectual property rights assigned to UT Dallas and agreements to share in royalties related to such rights;
  2. interests, and income from such interests, held in investment vehicles, such as mutual funds and retirement accounts;
  3. Gifts received from immediate family members; and,
  4. travel that is reimbursed or sponsored by UT Dallas, a Federal, state, or local government agency, 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.

Researchers are also required to disclose any of the above interests for immediate family members that may create the possibility for a conflict of interest.

Please visit our Case Studies page for situational examples that illustrate the kinds of relationships that involve outside activities and interests that require action under UTD policy.

Please contact the Conflict of Interest Manager if you are unsure whether you need to disclose an outside interest.

Review, Management, and Resolution of Identified Conflicts of Interest

A conflict of interest exists when a researcher’s outside interest could directly or significantly affect the design, conduct, or reporting of research at the University. The presence of a conflict of interest does not mean that there has been or will be a misdeed; however, failure to disclose a conflict of interest may properly be viewed as a misdeed. An unreported conflict of interest may result from a failure to disclose a conflict of interest or, even more seriously, a false certification of the absence of a conflict of interest. Failure to report or providing a false certification of a conflict of interest constitutes noncompliance with the policy and may be cause for disciplinary action.

The Research Integrity Committee, with assistance from the Office of Research Compliance, assumes a leadership role for reviewing identified conflicts in coordination with the dean of the school of the research investigator and the Office of the Provost, unless either office also has a conflict of interest related to the situation. Conflict of interest situations are reviewed independently by a Conflict of Interest Management Plan Review Panel, which makes recommendations as to how the potential conflict can be managed, reduced, or eliminated.

Outside Activities for Faculty and Research Employees

UT Dallas has implemented the policy on Conflicts of Interest, Conflicts of Commitment and Outside Activities to help faculty and staff members to manage their outside activities and avoid situations that may create a conflict of interest or commitment with their institutional responsibilities to UT Dallas. This policy ensures UT Dallas faculty and staff members can comply with the terms of UT Systemwide Policy 180.

Faculty members and research employees comply with the policy on Conflicts of Interest, Conflicts of Commitment and Outside Activities by completing the policy compliance training and, if needed, completing the Conflict of Interest and Commitment Disclosure. The policy compliance training describes the terms of the policy that apply to faculty and research employees, and provides a brief survey to help determine if a faculty or research employee has an outside activity that requires prior approval under the policy. UTD faculty members and research employees need to request approval for certain outside activities on an annual basis, and throughout the year as they engage in new outside activities that require prior approval. Please visit the Disclosure Portal for more information about the policy compliance training and disclosure tool.

The Institutional Official has delegated responsibility and authority for the approval of outside activities to the following offices:

• For members of the faculty: Dean or Department Chair • For deans and department chairs: Provost • For executive officers: The President • For administrative and professional staff: Supervisor

UTD Policy: Conflicts of Interest, Conflicts of Commitment, and Outside Activities (Printable and Adobe Acrobat formats)

UT System Requirements

The University recognizes that there is value in encouraging faculty and research employees to participate in activities outside of UT Dallas. Such activities often contribute to the mission of the institution and can provide important elements of employee development. UT System rules state an employee may accept outside employment or provide consultative or professional services with requisite approval by the appropriate UT Dallas authority prior to engaging in the activity. Such outside activities must not impair or interfere with an employee’s judgment in performing his or her institutional responsibilities on behalf of UT Dallas.

Faculty Time

Members of the faculty have flexibility in using their time to prepare for teaching and engage in research and other scholarly activity. During the term(s) of their appointment, faculty members are permitted to engage in outside activities on University Time no more than one day per week, averaged over the semester(s) of the faculty member’s appointment or period of employment. University Time is understood as the number of hours per week necessary for the faculty member to perform his or her institutional responsibilities. The following stipulations apply to outside activities conducted on University Time:

  • Time not used in one semester may not be carried over into another semester during which the faculty member is employed by UT Dallas.
  • Activities engaged on University Time require prior approval.
  • Activities engaged on University Time cannot be related to a conflict of interest, cannot interfere with the faculty member’s Institutional Responsibilities, and should clearly contribute to the mission of UT Dallas or provide important elements of faculty professional development related to the faculty member’s institutional responsibilities.
  • Exceptions to exceed this standard may be granted only with express approval by the President.

Part-time faculty and research employees are only required to request approval for outside activities that are related to a conflict of interest managed with UT Dallas.

Outside Activities that Require Prior Approval

As defined under UT System policy, approval is required for full-time faculty and research employees prior to engaging in the following activities:

  • Compensated activities that are related to the employee’s institutional responsibilities.
  • Activities, including uncompensated service as a member of an outside board, that are professional in nature and are related to the employee’s institutional responsibilities. Such activities should clearly contribute to the mission of UT Dallas or provide important elements of professional development and may be performed by faculty members on University Time with prior approval.
  • An activity that is related to a conflict of interest managed with UT Dallas.

The following activities do not require approval:

  • Activities engaged in by full-time faculty members appointed on a 9-month basis during those months in which the faculty member is not appointed, unless the outside activity is related to a conflict of interest.
  • Activities, including service on an outside board, that are personal in nature and are not related to the employee’s institutional responsibilities, including for organizations of the following nature: municipality; local religious congregation; neighborhood association; public, private, or parochial school; political organization; social advocacy organization; youth sports or recreation league; affinity group such as the local orchid society; and other similar boards
  • Activities conducted by faculty members as part of scholarly work, including:
    • Serving on a federal, state, or local government agency committee, panel, or commission;
    • Acting in an editorial capacity for a professional journal;
    • Reviewing journal manuscripts, book manuscripts, or grant or contract proposals;
    • Attending and presenting talks at scholarly colloquia and conferences;
    • Developing scholarly communications in the form of books or journal articles, reviews, movies, television productions, and similar works, even when such activities result in financial gain, consistent with intellectual property and other applicable UT System and institution policies and guidelines;
    • Serving as a committee member, an officer, or board member of a professional or scholarly society, or school board; and,
    • Accepting a commission for an architectural work or artistic work or performance that is considered an integral part of a faculty member’s academic portfolio.

Please visit our Case Studies page for situational examples that illustrate the kinds of relationships that involve outside activities and interests that require action under UTD policy.

Please contact the Conflict of Interest Manager if you are unsure whether you need to request approval for an outside activity.

Review and Management of Conflicts of Commitment

A conflict of commitment is a situation in which an outside activity directly or significantly interferes with an employee’s judgment in performing his or her institutional responsibilities, or a situation in which an employee uses UT Dallas, U.T. System or State of Texas resources without authority or approval in connection with an outside activity or interest. Generally, outside activities must not interfere with a faculty member or research employee’s performance of his or her institutional responsibilities. In the rare cases where a conflict of commitment situation can be effectively managed, management plans are developed by the employee and the employee’s approval authority, and must be approved by the next senior official.

Contact

Conor Wakeman
Conflict of Interest Manager

Sanaz Okhovat
Senior Director of Research Compliance