Conflict of Interest Situations with Possible Management Plans
Adjunct/Transitional Situations
From time-to-time a Faculty member may find themselves in a transitional situation when moving from one institution to another. Frequently, these individuals will either take a leave of absence or retain an adjunct faculty appointment which allows them to complete their work on any open research projects and /or to fulfill mentoring obligations to students.
Typically, these situations present such minimal conflict of interest risk that, unless there are more complicating factors, no formal management plan is required beyond the initial disclosure to the conflict of interest committee.
Example 1: Transition with minimal risk
Professor Z has accepted a position at another institution. In order for Professor Z to complete the work on any open sponsored projects at the UM and/or to provide access to Professor Z by his/her graduate students who are in the process of completing their studies, Professor Z will retain an Adjunct appointment at the UM during this transitional period.
This situation presents minimal risks and falls into what the COI committees refer to as an "Administrative Shunt” category. Management solutions may include the appointment of an ombudsperson to monitor the academic progress of the student(s) working with Professor Z.
Example 2: Transition with more than minimal risk
Professor Z has accepted a position at the University Michigan. Professor Z is the PI of a large federally sponsored project at his/her former institution, the University of ABCZ, which is not scheduled to end for another year. In order to fulfill the obligations to the federal sponsor, a portion of this project will be subcontracted to the UM under the direction of Professor Z. Professor Z will retain an adjunct appointment at his/her former institution so that he/she can continue to oversee and direct the work conducted on this project there.
This situation presents more than minimal risks. The example solutions provided below are intended to be a guide for demonstrating how particular conflict situations may be managed [note: the details of some situations may make COI management unworkable and the project will not commence]. The examples are not intended to be all-inclusive as each individual situation may require a greater or lesser degree of management based upon the elements of risk presented.
- Appoint a different faculty member, who has no connection to the UM, as PI of the project at the University of ABCZ. The new PI oversees all aspects of the subcontract to the University. This minimizes the conflict of interest for Professor Z.
- Appoint a different faculty member, who has no connection to the University of ABCZ, as PI of the UM project and allow the original faculty member (Professor Z) to serve as co-investigator. The new PI oversees all aspects of the subcontract. This becomes a managed conflict of interest for Professor Z (see notes below).
- Although the least desirable, if the technical work requires that Professor Z remain as PI at both the UM and the University of ABCZ, another individual with no connection to the University of ABCZ is appointed to oversee the performance of the subcontract (although this individual may not participate in the research activity) (see notes below).
- For examples B & C the following additional management conditions may apply:
- None of these examples require disclosure to and approval by the Regents under the State of Michigan Conflict of Interest Statute.
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Notes:
Professor Z would disclose his/her University of ABCZ connection to lab staff, students, oversight committees (IRB, UCUCA), as well as in any publications about the research. Annual evaluations of staff or key personnel involved in the project would not be the sole responsibility of Professor Z; additional oversight would be provided by a higher-level academic administrator. If human subjects are involved in the research, the new PI or another individual with no connection to the University of ABCZ would oversee all aspects of human subject participation.