Overview

Demonstrating transparency and objectivity in research is important for higher education, academic journals, and professional organizations in order to maintain credibility and influence. When an RCOI Management Plan is in place, its purpose is to mitigate a potential or perceived research conflict of interest by describing a set of controls and transparency requirements, but it does not eliminate it. The potential research conflict of interest (real or perceived) exists for as long as the significant financial interests and/or outside activities generating it are in place. Therefore, it would be incorrect for an individual with an RCOI Management Plan to say or consider that they "do not have a conflict of interest" simply due to RCOI disclosure to the University or having an active RCOI Management Plan.

Sponsoring agencies, research journals, professional societies, and conference presentations may have general or specific rules for recognizing potential research conflicts of interest. These can be broadly based disclosure requirements or specific to the subject matter. In instances where a potential RCOI may impact (or be perceived to impact) an activity with these organizations or their processes, individuals must disclose their RCOI in accordance with the requirements of their approved Management Plan in addition to the requirements of these organizations.  Sometimes, disclosures require judgment on a case-by-case basis depending on the relationship between the activity (proposal submission, planned publications, etc.) contemplated and its relevance to the individual's RCOI. For example, in the case of submitting proposals to sponsoring agencies, since the RCOI Committee is not reviewing all proposals submitted by researchers with Management Plans, the initial assessment is the responsibility of the individual with the RCOI to consider the content, specific aims, and collaborators of the proposal in order to determine if an RCOI disclosure must be made to the granting agency according to their rules and requirements. This assessment must take place independently for each proposal since the determination is specific to the project and its subject matter. The RCOI Committee can provide assistance if the faculty member is unsure about the relatedness or need for disclosure. However, in this instance; judgment is based on the substance of the proposal and its potential relevance to the RCOI, and by no means is the potential conflict absolved or no longer in existence simply because a Management Plan is in place.

Therefore, it is important that authors, editors, and reviewers provide full disclosure to mitigate or eliminate perception of any financial or personal gain that may be obtained through research described in publications, presentations, or grant proposals. Many publications and organizations have specific requirements and standards for disclosure of related financial interests and board service relationships. 

When to Provide Disclosure

When a potential research conflict of interest exists and a disclosure is required in publications, presentations, and grant proposals, it must be provided in cases of real and perceived RCOIs:

• Real Research Conflicts of Interest: Real RCOIs include significant financial interest, IP, or other relationships that could potentially bias the research being reported in the publication/presentation. Service on a board such as CEO or President of a company is considered a financial interest. These RCOIs could be possible in cases of outside employment, being a consultant, ownership in a private company, income from intellectual property, board service, or similar relationships/interests of your spouse and/or dependents.
• Perceived Research Conflicts of Interest: Any of the interests or relationships described above, if they could be perceived to be related to your UTA research or responsibilities. If the outside activities are focused on or working with an outside entity that focuses on products or research that could be perceived by a reasonable person to be related to what you do at UTA, then a disclosure should be provided in the publication/presentation to alleviate the potential RCOI and provide transparency. 

How to Provide Disclosure

• Publications: In publications, you must comply with the RCOI disclosure policies of the publisher or journal. If the publisher/journal does not have an explicit policy on disclosing conflicts of interest, you should provide disclosure whenever possible in order to provide full transparency and protect the integrity of your work. See "Example Disclosure Statement" below for guidance; however, the statement may need to be altered in order to fit the context or guidelines of the particular journal. 
• Presentations: In presentations, you must provide a disclosure statement in your presentation for any real or perceived RCOIs as defined above. See "Example Disclosure Statement" below for the minimum information to be included. You may add additional details as you deem necessary. 
• Grant Proposals: In grant proposals, you must disclose your RCOI in accordance with the requirements of your approved Management Plan in addition to the requirements of the granting agency. The RCOI Committee does not review proposals submitted by all researchers with Management Plans. The initial assessment is the responsibility of the individual with the RCOI to consider the content, specific aims, and collaborators of the proposal in order to determine if an RCOI disclosure must be made to the granting agency in accordance with their rules and regulations.

Example Disclosure Statement

[Dr. /Mr. /Ms. name] has a potential research conflict of interest due to a financial interest with company [name of entity]. A management plan has been created to preserve objectivity in research in accordance with UTA policy.