Conflict of Interest

Published October 15, 2014

The University at Buffalo is a proponent of transparency and protecting the public trust.  For many years, UB and the State of New York have had programs, policies and practices in place to deal with conflict of interest.  These policies and practices have been adjusted over time to make them more effective and to assure that they comply and comport with applicable laws, regulations and agency guidance.

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The University at Buffalo has well-established policies and procedures for conducting research, disclosing potential conflicts of interest and working compliantly with industry.   These safeguards help ensure that no UB faculty activity is unduly influenced by the industry and help assiduously avoid even the perception of a circumstance in which one’s personal interest or relationships might compromise education, research or integrity at the university.

All UB employees, including faculty physicians that practice in partner organizations, are subject to UB related policies pertaining to conflict of interest. 

While all relationships involve differing priorities and interests, the concern is that the duality of interests can become or can create the perception of conflicts that compromise education, research, or the integrity of the field. While this duality has been recognized for many years, because of decreases in support for the educational and research missions of academic institutions from federal and other traditional funding agencies, academic departments increasingly look to other sources to support such vital functions.

All UB faculty are subject to UB conflict of interest policies, the SUNY Joint Commission on Public Ethics, and are required to make financial conflict of interest disclosures.   Each faculty is required to complete an Annual Financial Disclosure form at the time of applying for funded research or prior to the release of grant funds, whichever occurs first, annually thereafter, and within 30 days of discovering or acquiring a new significant financial interest (SFI).  UB carefully reviews these conflict of interest disclosures and effectively manages any conflict of interest cases and reports to appropriate federal agencies as needed.

In 1995, the University established an investigator conflict of interest policy requiring investigators to disclose their and their immediate family members significant obligations, significant financial interests that is related to their institutional responsibilities to provide the reasonable expectation that the design, conduct, or reporting of funded research by UB faculty, students, or staff will not be biased.   In 2012, UB updated the Investigator Conflict of Interest Policy to fulfill the requirements of the revised Public Health Service policy that went into effect August 24, 2012

In 2012, the Jacobs School of Medicine and Biomedical Sciences at Unviersity at Buffalo established the Jacobs School of Medicine and Biomedical Sciences at University at Buffalo Conflict of Interest Disclosure policy to ensure that no activity of the SMBS and its members is unduly influenced by industry, and that we assiduously avoid even the perception of abridgment of the implicit trust (which is based both on reality and perception) the public places in us to practice in the best interests of our patients and with the greatest integrity.   A revised policy is currently under review and will provide further provisions to mitigate conflict of interest.

Several significant changes have taken place in 2013 in the university's efforts to address the issue of conflicts of interest in research.  UB established the Institutional Conflicts of Interest in Human Subjects Research Policy to protect the rights and welfare of human subject research participants and to ensure research integrity.  All potential Institutional Conflicts of Interest in human subjects research require disclosure, evaluation, and management or elimination.  A new UB Conflict of Interest in Research Committee (CIRC) was established in compliance with new federal regulations. The establishment of CIRC and other changes are reflected in the revised UB Investigator Conflict of Interest policy.

UB activities are also subject to SUNY RF’s Policy on Conflicts of Interest in Public Health Service Sponsored Programs and SUNY RF’s Conflict of Interest Policy.  SUNY and RF Investigators may not have any interest or engage in any outside activity that results in an unmanaged Financial Conflict of Interest. To this end, SUNY and RF Investigators must disclose their interests and outside activities, and those of a related party, which may affect their independent and objective performance of their PHS-funded project(s). Financial Conflict of Interest shall be subject to management plans, and compliance with such management plans shall be monitored.  In addition, Research Foundation Board Members, Officers, and Employees may not have any interest or engage in any outside activity that results in an unmanaged conflict of interest. To this end, Board Members, Officers, and Employees must disclose their interests and outside activities, and those of a Related Party, which may affect their ability to perform their duties with independence and objectivity. A conflict of interest must be managed so the conflict is reduced or eliminated, and compliance with conflict of interest management plans should be monitored where necessary.

UB encourages innovation by faculty and staff to fulfill our mission of delivering new knowledge and biotechnologies for public benefit.   Transparency and Conflict of interest oversight contributes to our unquestioned commitment to safety in our programs and services, and to scientific objectivity as we develop potentially beneficial discoveries.


Industry Support for University Research

Conflict of Interest and UB Policy

Management and Disclosure Process