Conflict of Interest

The UC San Diego Conflict of Interest Office provides comprehensive and confidential assistance to all faculty, staff, non-senate academics, and postdoctoral trainees to review and advise on situations in which a personal or financial interest may compromise or appear to compromise the judgment of the employee with respect to the administration of their job responsibilities at the University. 

For detailed information on the services that the COI Office provides and a list of resources and general guidance on conflicts of interest, please visit the COI Office's website on Blink or contact them at (858) 534-6465. 

Relevant Policies

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What is a "Conflict of Interest" (COI)?

A Conflict of Interest is a situation in which financial or other personal considerations may compromise or have the appearance of compromising an employee’s professional judgment in administration, management, teaching, research or any other professional activities. In health care, it often arises in the context of purchasing, prescribing, research, and investments.

A Conflict of Interest occurs when (1) an employee has a significant financial interest in a company that is providing funding for the employee’s research or other University activity or (2) the employee’s research might directly and significantly affect the significant financial interest of an employee responsible for the conduct of a research project.

What are the risks of a potential Conflict of Interest?

  • Appearance of impropriety – influence on clinical decisions and drug / device prescribing on teaching, research, patient care / trust, and purchasing decisions
  • Compromise integrity – scientific studies & publications
  • Conflict of time commitment and effort • Failure to recognize the UC intellectual property & interests
  • Improper channeling of funds (research and other funds)
  • Misuse of UC facilities, resources, funds and personnel
  • Violations can be costly:
    • Civil monetary penalties (up to $5,000 per violation), misdemeanor criminal penalties, exclusion from federal health care programs, loss of job, license, career impact, adverse publicity
    • University policy does not permit indemnification and defense where an employee engages in intentional illegal activity.

How do conflicts arise?

  1. You have a material financial interest (personal or private);
  2. You participate in, influence, or make the decision, in your official duties / responsibilities as a UC employee; and
  3. The decision is going to materially effect your financial interest.

All three components are required to have a conflict under the California Political Reform Act laws.

Examples of potential conflicts.

  • Anti-Kickback Statute – You admit or refer patients to an entity in exchange for money, discounts or other referrals to you.
  • Stark Law – You refer patients to an outside entity in which you have a financial interest.
  • False Claims Act – You submit a professional fee claim for payment for services which were not provided.
  • California PRA – You recommend a product and are on the company’s board of directors.
  • University Policy – You fail to disclose financial interests in a research project.
    • UC Policy for Sponsored Research: “Disclosure of Financial Interests & Management of Conflict of Interest Related to Sponsored Projects”, stipulates that an Investigator (any UC employee responsible for the design, conduct, or reporting of a sponsored project at UC) may be required to disclose significant personal financial interests related to that project.

How to disclose COI and other financial interests.

  • Disclosure Forms:
    • Research grants and clinical trials: 700-U form
    • Clinical service agreements: 700-U form
    • Annual disclosure of outside professional activities (APM 025 / APM 671)  
    • Prior Approval for Category I activities (Academic Faculty)
  • Disclosure to Others:
    • Conflict of Interest Office  
    • Health System Pharmacy & Therapeutics (P&T) committee
    • Patients -- via the consent form for anesthesia, surgery and other procedures
    • Purchasing and Procurement Offices
    • Intellectual Property &Technology Transfer
    • CME event learners (disclose partial support from industry)
    • Publications (disclose partial support from industry of other grants)