Conflicts of Commitment and Interest Policy Overview

Conflict of Commitment

Stanford faculty members owe their primary professional allegiance to the University, and their primary commitment of time and intellectual energies should be to the education, research and scholarship programs of the institution. The specific responsibilities and professional activities that constitute an appropriate and primary commitment will differ across schools and departments, but they should be based on a general understanding between the faculty member and his or her department chair and school dean.

Even with such understandings in place, however, attempts of faculty to balance University responsibilities with external activities--such as consulting, public service or pro bono work--can result in conflicts regarding allocation of time and energies. Conflicts of commitment usually involve issues of time allocation. Whenever an individual's outside professional activities (as defined in RPH 4.3, Stanford’s policy on Consulting and Other Outside Professional Activities) exceed the permitted limits (normally thirteen days per quarter), or whenever a full-time faculty member's primary professional loyalty is not to Stanford, a conflict of commitment exists.

Due to conflict of commitment concerns Stanford prohibits:

If a situation that raises questions about a possible conflict of commitment arises, faculty should discuss the situation with their department chair or school dean, or the Dean of Research.

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Conflict of Interest

Stanford University is an institution of public trust; faculty must respect that status and conduct their affairs in ways that will not compromise the integrity of the University or that trust.

A conflict of interest occurs when there is a divergence between an individual’s private interests and his or her professional obligations to the University such that an independent observer might reasonably question whether the individual’s professional actions or decisions are determined by considerations of personal financial gain. Such situations do NOT necessarily imply wrong-doing or inappropriate activities. However, in a research university setting, they can compromise, or be perceived as compromising, important academic values, research integrity, or the university mission. At Stanford, it is essential for all faculty, staff, and students to understand how these divergent interests can become a problem and how they should be disclosed and managed.

Conflicts of interest often arise at the intersection of two fundamental missions: to push the boundaries of knowledge and to transfer that knowledge to the private sector for the benefit of the public. There may be, for example, significant personal financial incentives related to outside consulting, patenting and licensing an invention, or being involved with a ‘start up’ company. Considerations of personal financial gain however must not influence the decisions or actions of individuals in carrying out their University responsibilities. The perception that such incentives might harm research objectivity, the protection of human subjects, or adversely affect other institutional responsibilities in the areas of education, clinical care or administrative activities is enough to mandate that such conflicts be identified, and then be eliminated, mitigated, or managed.

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Consulting Policies

Stanford policies concerning the outside professional activities of Stanford personnel include: Consulting and Other Outside Professional Activities By Members of the Academic Council and Medical Center Line Faculty (RPH 4.3), which applies to faculty, the Conflict of Commitment and Interest for Academic Staff (RPH 4.4) policy and the Staff Policy on Conflict of Commitment and Interest (http://adminguide.stanford.edu/15_2.pdf) for all other staff. The staff policies only permit consulting with the written permission of the department/program chairman, or by the principal investigator or by the director of the appropriate library, relative to the specific appointment of the staff person.

In addition to the limit set on the time that a full time faculty member may spend on outside consulting, Stanford's policy also prohibits:

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Conflicts of Interest in Research

Conflicts of interest are common and practically unavoidable in a modern research university. Conflicts of interest can call into question the professional objectivity and ethics of the individual, and reflect negatively on the University. Opportunities to profit from research may influence or appear to influence the choice of the direction of the research, the design and conduct of the research, objectivity of the data, or interpretation of research results. Moreover, in human research, these opportunities to profit may influence or appear to influence a researcher's judgments about which human subjects to enroll, the clinical care provided to subjects and the proper use of subjects' confidential health information, and may create biases in study design, data collection and analysis, adverse event reporting, or the presentation and publication of research findings. On the other hand, there may be special circumstances that create compelling reasons for an individual to engage in research involving human subjects despite having a financial conflict of interest.

Stanford seeks to help faculty, staff and students in translating their discoveries and developments as part of its mission to benefit the public. The university also seeks to minimize the adverse affects of conflicts of interest, and to advise faculty and staff on how to avoid, mitigate, or, if warranted, how to manage those conflicts. The purpose of Stanford’s Faculty Policy on Conflicts of Commitment and Interest (RPH 4.1) and policies on consulting and other professional activities is to describe the risks, explain the requirements for how faculty, staff and trainees must address these risks through disclosure and provide information about the standards and processes that Stanford uses to review and assess personal financial interests related to university responsibilities. In addition, research funded by the Public Health Service (PHS) and National Science Foundation have specific requirements that are covered in PHS and NSF Requirements Regarding Financial Disclosures and Agency Notifications (RPH 4.2).

See also:

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Disclosure of Personal Financial Interests

All faculty investigators, and any other non-faculty participants in the research, who have responsibility for the design, conduct, or reporting of the research, must disclose any personal financial interests that reasonably appear to be related to the project.

Personal financial interests in a company may reasonably appear to be related to the research/scholarship if that company/organization:

The financial interest thresholds defined as significant financial interests (SFI) by the Public Health Service (PHS) (see RPH 4.2 for further information) are as follows:

While most disclosures of financial interests will be deemed de minimus or not significant in terms of potential effects on the individual’s ability to perform his or her duties without risk of bias, financial interests above thresholds will automatically be deemed significant conflicts of interest and will require closer scrutiny and possible elimination, mitigation, and/or management.

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Assessing Conflicts of Interest in Research

Financial interests above thresholds that are disclosed and deemed to be related to a faculty member’s research responsibilities will be further reviewed to determine if the financial interest or relationship could have a direct and significant effect on the faculty member’s performance of his or her research. In addition, we need to ensure that:

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Eliminating, Mitigating, or Managing Conflicts of Interest in Research

If it is determined that a significant financial interest could have a direct and significant effect on the research, and/or the research on the financial interest, the conflict will need to be eliminated or managed according to a plan provided to the faculty member by the Cognizant dean for COI. Other administrative actions, such as disclosure in publications and public talks, may be required when the financial interest is not considered likely to directly and significantly affect performance of research.

Some common strategies for eliminating, mitigating, or managing conflicts include:

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Other Requirements for PHS-Funded Research

Additional requirements under regulations for PHS-funded research include:

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Conflicts of Interest in Teaching and Educational Activities

Education and guidance given to students by faculty, including the nature and direction of research or other studies, should be governed by what is in the academic interest of the student. In addition, personal financial interests should not influence the content of any educational activity or presentation at Stanford or elsewhere when given to students or the public and any personal financial interests related to the educational activity should be disclosed. A financial interest in a company/organization could create a conflict of interest related to institutional responsibilities for education if that company/organization:

Such conflicts need to be disclosed and reviewed by the Dean, Cognizant dean, or COI Program administrator to ensure that such interests do not negatively affect students and trainees.

In addition, the School of Medicine has several specific policies addressing educational conflicts of interest. The policy on Commercial Support of Continuing Medical Education has prohibited the direct support of topic specific Continuing Medical Education (CME) by the commercial sector. Support from industry for CME will be considered only in the following general categories:

The School of Medicine’s Stanford Industry Interactions Policy [SIIP] requires that non-CME educational activities supported by industry be designated for broadly defined areas only, not involve promotion or marketing, and that industry not influence the curriculum, among other things. Conflicts of interest must be disclosed to the learners.

Industry support for educational activities involving medical and graduate students, and postdoctoral fellows and trainees must be approved by the Senior Associate Dean for Education.

SIIP also prohibits industry-sponsored "speakers bureaus” (i.e., contractual relationships to give talks in which the topic(s) and/or content are provided by the company) and dedicated marketing and training programs designed solely or predominantly for sales or marketing purposes.

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Conflict of Interest in Administrative Responsibilities

Stanford policy on conflicts of interest applies to administrative duties carried out on behalf of the institution. A financial interest in a company/organization could create a conflict of interest if:

These conflicts of interest need to be reported and reviewed by the Dean, Cognizant dean for COI, COI Program administrator, or if human subjects research is involved, by the Institutional Conflict of Interest Committee (ICOIC).

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Conflict of Interest in Clinical Care

Stanford School of Medicine has a policy on Conflicts of Interest in Clinical Care which recognizes that physicians have a unique opportunity to improve patient care through collaboration with industry. However these interactions must take place in an atmosphere of high integrity and transparency so that collaborations with industry can optimally benefit patients and improve human health and well-being. Accordingly, Stanford physicians are expected to fully disclose financial relationships with companies that produce, manufacture or provide medical devices, implants, pharmaceuticals, biologics, diagnostics, or other medical care related products that may be used in the care of their patients. A financial interest in a company could create a conflict of interest if:

Clinical care conflicts need to be reviewed by the Senior Associate Deans for Clinical Affairs.

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Faculty Industry Relationships

In order to foster transparency for patients and the public, the School of Medicine posts disclosures of financial interests or relationships related to faculty consulting activities that reasonably appear related to a faculty member’s institutional responsibilities. This information is displayed under the 'Industry Relationships’ section on the faculty member’s faculty profile website, CAP, which is also used by the Stanford Hospital and Clinics and the Lucile Packard Children’s Hospital in their Find a Physician directory.

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