Payments for Services (Consulting, Lectures, Advisory Board Payments, Or Honoraria);

A financial conflict of interest (FCOI) occurs when an outside activity, position, or financial interest does or could appear to influence your research or other work for Duke (as applicable). These include:

·  Payments for services (consulting, lectures, advisory board payments, or honoraria);

·  Equity interests, i.e. stocks, stock options, and other ownership interests;

·  Intellectual property rights (e.g., licenses and royalties);

·  Gifts, gratuities, or donations; and

·  Sponsored or reimbursed travel.

The U.S. government through the Office of Management and Budget and each agency, and many state agencies, and private sponsors and foundations require that Duke ensures that research be objective and contracts be administered free from conflicts of interest.

For example, NIH, NSF, and other agencies require each “investigator” to submit a FCOI disclosure form. An “investigator” is anyone responsible for the design, conduct, or reporting of the research, including a collaborator or consultant. Implementing these requirements and its own policy, Duke requires the following individuals to submit a disclosure form:

a.  Paid faculty;

b.  Individuals with a FCOI identified in the previous year;

c.  Other individuals identified on federal grants involved in the design, conduct, or reporting of research;

d.  Investigators and other individuals identified on IRB applications involved in the design, conduct, or reporting of research;

e.  Individuals with intellectual property (IP) used in research at Duke; and

f.  Individuals with significant financial and administrative responsibilities that include procurement.

Examples of Conflicts

•  Owning shares in a privately held outside entity and your grant is designed to advance that entity’s interests.

•  Cherry picking the best data from your research to bolster the value of licensed intellectual property.

•  Making procurement decisions that favor a company for which you have an ownership interest.

•  Accepting gifts, favors, or hospitality from current or potential vendors.

Outside financial interests must be disclosed at least annually and within 30 days of acquiring or discovering a relevant financial interest.