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Managing Conflicts of Interest

The conflict of interest management plan should address how Virginia Tech and the individual(s) involved will ensure objectivity of the research being conducted and document the clear separation of the personal interests and university responsibilities of the investigator.  The goal is to ensure that personal interests of any individual do not improperly influence the design, conduct, or reporting of research, or relationships with the sponsor, university colleagues, or students.    Principles of transparency, separation, independence, and oversight guide the review of the potential conflict and any proposed management plan.

Key elements of the management plan include:

  • Role and principal duties of the conflicted investigator in the research project
  • Conditions of the management plan, including involvement of students, postdocs, and employees if applicable
  • How the management plan is designed to safeguard objectivity in the research project
  • Confirmation of the investigator’s agreement to the management plan
  • How the management plan will be monitored to ensure investigator compliance
  • Other information as needed

An acceptable management plan usually includes a combination of strategies, such as:

  • Targeted public disclosure of the nature of significant financial interests, in publications and presentations, to sponsors, collaborators and trainees, patients, staff, or research participants (view sample disclosure statement to a journal);
  • Assignment of co-chair for student or postdoc advisees;
  • Financial management of research project by independent party such as a department head;
  • Assignment of principal investigator status to a neutral senior colleague with appropriate expertise;
  • Independent monitoring by independent reviewers;
  • Disqualification from participation in all or a portion of the activity;
  • Reduction or divestiture of significant financial interests; and/or
  • Severance of relationships that create actual or potential conflicts.   

Awards will be contingent upon acceptance and implementation of the management plan.  University officials, not the faculty member, ultimately determine whether an award can be accepted or must be declined given the possible unresolved conflicts of interest. 

Example scenarios

  1. Subcontract with no involvement of faculty owner
  2. Financial interest/Graduate student involvement
  3. Subcontract with Conflicted investigator
  4. Virginia Tech subcontract to employee-owned business
  5. Employee spouse involved in a sponsored project

Example management plans and statements