Financial Conflicts of Interest in Sponsored Research

Approved April 26, 2002

Revised September 10, 2009
Revised October 25, 2011
Revised November 15, 2012
Revised March 29, 2017
Reviewed February 12, 2020
Revised May 7, 2026

Next Scheduled Review: May 7, 2031

Supplements System Policy 15.01, System Regulation 15.01.03

Rule Summary

Texas A&M Engineering Experiment Station (TEES) is committed to conducting research in a manner consistent with the highest standards of integrity and ethics. This rule is adopted to promote objectivity in research and to ensure that research activities are conducted in a manner free from bias resulting from financial conflicts of interest (FCOI).

Procedures and Responsibilities

1. APPOINTMENT OF CONFLICT OF INTEREST OFFICIAL

- The Agency Director appoints the Deputy Director or designee as the Conflict of Interest Official (COI Official) for TEES. The COI Official will perform the duties established in System Regulation 15.01.03 relating to the review of financial interest disclosures and the management and reporting of FCOI.

2. DISCLOSURE AND REVIEW

- Each Investigator, as defined in System Regulation 15.01.03, must disclose significant financial interest (SFI), and submit Financial Disclosure Statements to the TEES COI Official as required in System Regulation 15.01.03.
- 2.1 – In accordance with System Regulation 15.01.03 and federal regulations, the COI Official will review all financial disclosure statements by Investigators and determine whether any disclosed SFI is related to the Investigator’s research and whether an FCOI exists.
- 2.2 – The COI Official may appoint a Conflict of Interest Review Committee (CIRC) to assist in the determination of whether an FCOI exists. The COI Official and/or CIRC may involve the Investigator and/or Division Head(s) to assist in determining whether an SFI is related to the Investigator’s research or research activities. The System Chief Research Compliance Officer and/or the Office of General Counsel may be consulted as appropriate.

3. MONITORING

- Each Investigator conducting Research under a Management Plan must comply fully and promptly with the plan. Each person identified for oversight responsibility in the plan must carefully monitor compliance and must notify the COI Official of any non-compliance or if they can no longer perform the oversight duties outlined. The COI Official will be responsible for conducting periodic reviews of Financial Disclosure Statements and Management Plans to determine individual and institutional compliance. The COI Official must report instances of noncompliance as required in System Regulation 15.01.03 and federal regulation.

4. TRAINING AND CERTIFICATION

- Investigators must complete training as required in System Regulation 15.01.03. In addition, each Investigator must annually certify that the Investigator is aware of and has read System Regulation 15.01.03 and this rule and is aware of the Investigator’s responsibilities regarding disclosure of SFIs and applicable federal regulations.

5. PUBLIC ACCESSIBILITY

- 5.1 – The COI Official will ensure that this rule is available through a publicly accessible website.
- 5.2 – If the COI Official determines that an FCOI exists that is related to Public Health Service (PHS)-funded research, the COI Official must coordinate with the public information officer to make information, defined in System Regulation 15.01.03, available in writing to any requestor within five business days after receipt of a request, so long as the Investigator still holds the SFI.
- 5.3 – Non-PHS-funded Research For all public information requests related to non-PHS funded research, the COI Official must coordinate with the public information officer to ensure that responses to requests comply with Texas Government Code, Chapter 552.

6. OTHER CONSIDERATIONS

- In addition to the issues addressed in System Regulation 15.01.03 and this rule, there may be other ethical considerations that are separate and distinct from conflict of interest questions, including but not limited to those relating to external employment and conflict of commitment. The primary responsibility of employees of TEES is the accomplishment of the duties and responsibilities assigned to the employee’s position of appointment. External consulting or other outside employment should not interfere with those duties and responsibilities as set forth in system policies and related regulations.