Conflict of Interest and Conflict of Commitment Comparison
Information that Must be Disclosed to UC Berkeley
This chart summarizes the conflict of interest and conflict of commitment policies under which faculty members and other investigators must disclose certain information to UCB in order to achieve compliance with federal, state, and university requirements. Additional details and links to policy are provided following the chart.
Comparison Chart
| Category | Conflict of Interest (COI) | Conflict of Commitment (COC) |
|---|---|---|
| Purpose | To protect the integrity and objectivity of research conducted by UCB investigators, and comply with related policies and regulations | To identify and manage outside professional activities of UCB faculty to ensure no interference with academic responsibilities |
| Who files | Principal Investigators and others who share responsibility
for the design, conduct or reporting of externally supported
research in conjunction with
| Faculty appointed at 50% or more and all Health Science Compensation Plan (HSCP) participants |
| What is filed | Depends upon source of funding
| Annual reports and prior approval requests for certain activities |
| When is filing required | Depends upon source of funding
|
|
| Filing required under policies established by |
| University of California
|
| Online systems | Phoebe | UC OATS |
| Office with administrative responsibility | Research Administration and Compliance | Academic Personnel |
Note: All involvement (funded or unfunded) with foreign entities must be disclosed.
Conflicts of Interest
- Principal Investigators on sponsored research agreements and others who share responsibility for the design, conduct, or reporting of research supported by the National Science Foundation and all other federal agencies other than PHS and DOE (see below), must disclose personal financial interests, both U.S. and foreign, that may reasonably appear to be affected by the work performed under the sponsored project. This includes salary, consulting payments, honoraria, royalty payments, dividends, loans from the entity, equity interests, or intellectual property interests in the form of a patent, patent application, or copyright of software assigned to any entity other than the UC Regents.
- Principal Investigators on sponsored research agreements and others who share responsibility for the design, conduct or reporting of research supported by the Public Health Service (including the National Institutes of Health) and the U.S. Department of Energy, must disclose personal financial interests that reasonably appear to be related to their UCB responsibilities. Financial interests include income, honoraria, royalty payments for use or sale of patented or copyrighted intellectual property owned by an individual or organization other than the UC Regents, equity, and travel reimbursed by or directly purchased for the individual. While there are some exclusions for U.S. government and institutions of higher education, all financial interests in foreign institutions must be disclosed.
- Principal Investigators seeking research support through contracts, grants, gifts and material transfer agreements from non-governmental sources (for-profit and non-profit) and others who share responsibility for the design, conduct or reporting of the research, or who are the recipients of gifts for research, must disclose financial interests in the sponsor under State of California, UC, and UCB conflict of interest policies and procedures. This includes all foreign sponsors including governmental and non-governmental.
Conflicts of Commitment
- UCB faculty are required to seek prior approval for outside professional activities likely to create conflict of commitment concerns. This includes the conduct of research elsewhere, employment at another institution, and managerial or executive positions outside the University. Faculty are also expected to submit annual reports in which they disclose these kinds of activities, and any outside consulting, Board of Director memberships, industry workshops, and UC-compensated teaching above their regular course loads. (See APM 025 and 671)
- UCB faculty are required to complete annual reports of outside professional activities, both those likely to create conflict of commitment concerns (listed above), and other activities including additional University-compensated teaching such as UNEX courses and programs, other continuing education programs run by the University, and self-supporting UC degree programs; consulting or testifying as an expert or professional witness; providing outside consulting services or referrals or engaging in professional practice as an individual or through a single-member professional corporation or sole proprietorship; serving on a board of directors outside of the University; providing or presenting a workshop for industry; or providing outside consulting or compensated professional activities performed for entities such as the Los Alamos and Lawrence Livermore National Laboratories. (See APM 025 and 671)
Reports of outside professional activities (whether compensated or uncompensated) must include all foreign and domestic activities. The UC-wide Outside Activity Tracking System (OATS) has been developed to facilitate this reporting, and provide current information on its implementation at UC Berkeley.