How are Conflicts of Interest Reviewed and Managed?

I completed my COI report. What happens next? If I need a management plan, what will it include and what will I need to do?

COI reports undergo a review process to identify whether a conflict of interest exists and, if it does, to manage the conflict. Here you will find information about the COI review process, standard management plan terms, and guidance related to management of more complex COIs.

How are COI reports reviewed to determine whether a Conflict Management Plan (CMP) is needed?

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First, COI reports undergo review by COI administrative staff

COI administrative staff are responsible for collecting and reviewing the COI reports submitted through the eCOI reporting system. A preliminary review is conducted to determine if there is a potential for a conflict of interest to exist, given the reporter’s interests in external entities.  COI staff may consult with reporters to obtain additional information or to clarify information in a COI report.

If a COI report does not show any relationships with external entities that present the potential for a COI, the review will be completed at this stage. COI staff will assign the COI report a status specifying the outcome of the review. Some common scenarios that do not involve a COI are:

  • The only relationships reported need not have been included in the COI report (unpaid work, Cornell appointments, work which ended before the beginning of a person’s Cornell appointment, work with U.S. government agencies, etc.);
  • The reporter was paid only a small amount which was not enough to create a COI;
  • The reported financial interests were not related to the person’s Cornell duties.

If COI staff determines that there is a potential COI, the FCOI Committee will complete the review

When a COI report reveals a relationship with an external entity that poses the potential for a conflict, the Financial Conflicts of Interest Committee (FCOIC) will review the relationship to determine whether a Conflict Management Plan (CMP) is necessary, and if any special management terms are needed. There are two types of FCOIC review:

  • Expedited review- Common scenarios that create a COI will undergo an expedited review by one member of the FCOIC, and will usually result in a simple Conflict Management Plan (CMP). The primary requirement in these plans is that the reporter disclose their relationship with the external entity.
  • Full Committee review - More complicated COIs are discussed by the full, convened FCOIC. The Committee determines how to manage the conflict, including drafting a CMP that specifically addresses any unusual circumstances. Full Committee reviews occur at monthly meetings, and require a quorum and vote. To assist in these reviews, the FCOIC involves representatives from the Office of Research Integrity and Assurance, the Office of Sponsored Programs, Cornell Center for Technology Licensing, and the Office of University Counsel.

What terms are typical in a Conflict Management Plan?

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Conflict Management Plans (CMPs) are put in place to address conflicts between a person’s external financial interests and their Cornell duties. Each CMP is designed to protect the integrity of Cornell research by eliminating any reasonable assumption that research results are biased by financial self-interests, while also allowing for the pursuit of entrepreneurial interests, and protecting the academic freedom and best interests of students.

Appointment of a Conflict Manager

A critical step in managing any COI is the appointment of a Conflict Manager (CM). Typically, department Chairs serve in this role. However, if the Chair has a relationship with the external entity managed under the CMP or participates in the research covered by the CMP, then the FCOIC will consult with the reporter and college leadership to identify another senior member of the faculty to serve as the CM.

The CM oversees compliance with the terms of a CMP, and acts as a resource to the reporter, and to any staff or students affected by the COI. See the Guide for Conflict Managers for more information.

Terms included in every CMP

A fundamental requirement for management of COIs is disclosure of the existence of the conflicting relationship. Each CMP requires the managed reporter to disclose the relationship with the external entity to students, fellows, postdoctoral associates, trainees and staff under their supervision; to collaborators in research that is related to the entity; to editors of journals; and to organizers of conferences where research results are presented that are related to the entity.

To see other terms typically included in a CMP, refer to this template management plan.

Annual confirmation of compliance

Each CMP requires that, at least every year, the managed person and their Conflict Manager meet to discuss compliance with the terms of the plan over the previous 12 months, to address any concerns or questions related to the CMP, and to complete a checklist confirming compliance with the plan.

What additional terms are included in a more complicated Conflict Management Plan?

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Management plans may be customized to address special circumstances not covered by a standard CMP, such as:

SBIR & STTR awards

If your CMP relates to a SBIR or STTR project, specific terms will apply at both the proposal stage and the award stage. For detailed information, please see the COI guidance for SBIR/STTR projects.

Research involving human participants

Protecting the rights and welfare of human research participants is an important role for all research personnel and the university. External commitments and financial interests that compromise or appear to compromise the rights and well-being of human research participants are therefore the subject of special scrutiny. For detailed information about COI requirements related to human subjects research, please click here.

Engagement in start-ups

Cornell University supports the efforts of its research personnel to participate in the development and dissemination of Cornell intellectual property by pursuing relationships with existing business entities and forming start-up companies. At the same time, the University must identify and appropriately manage potential conflicts of interest arising from these relationships to ensure the integrity of the research process, the unbiased and effective development of University IP, and the protection of its students. For guidelines on appropriate involvement in start-ups, please click here.

Can a Conflict Management Plan be appealed?

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Once a reporter has been notified that the FCOIC has decided to implement a CMP, they have two weeks to either agree to the plan in writing or to submit a written request to appeal all of a part of the CMP. The FCOIC has the authority to review appeals, and to either affirm their decision or amend the CMP. If the reporter disagrees with the FCOIC’s decision at this stage, they may submit a written request for reconsideration to the Vice President for Research & Innovation. The VPR may recommend to the FCOIC that a requirement be removed or changed, but may not require that the FCOIC alter or remove a requirement. The VPR has the discretion to add requirements to any CMP.

What are the consequences of not complying with a Conflict Management Plan?

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Non-compliance with a CMP could put into question the integrity of Cornell research, inhibit academic freedom and open dissemination of research results, and adversely affect Cornell’s ability to seek and maintain sponsor funding for research. Violations of the COI policy, including non-compliance with a CMP, are therefore handled swiftly and firmly. For more information, please visit this page: Non-compliance with COI Policy.