Research Conflicts of Interest (RCOI)

Research Conflicts of Interest (RCOI)

The University of Tennessee at Chattanooga (UTC) is committed to ensuring that research is conducted objectively and free from bias resulting from financial or personal conflicts of interest. 

Conflicts of interest are not intrinsically a bad thing. UTC supports engagement with industry, innovation, and other outside organizations, but these activities may create research conflicts of interest that must be managed to protect the integrity of research, investigators, research participants, and the university. The purpose of the RCOI program is to ensure that perceived, potential or actual conflicts are identified, disclosed, and appropriately managed in accordance with university policy and federal sponsor requirements.

The research conflicts of interest process includes disclosure, review, and management

Key Definitions

Conflict of Interest (COI)

A Conflict of Interest exists when an individual’s personal, financial, or professional interests could compromise — or appear to compromise — their judgment, decisions, or actions in performing university responsibilities.

COI may apply broadly across university activities, including employment, purchasing, and research.

Research Conflict of Interest (RCOI)

A Research Conflict of Interest exists when an investigator’s financial, personal and professional interests could directly and significantly affect — or appear to affect — the design, conduct, or reporting of research.

RCOI specifically applies to sponsored research and research-related activities.

Examples include:

• Financial interests in a company related to sponsored research
• Consulting or advisory roles with entities sponsoring or benefiting from research
• Intellectual property interests connected to research outcomes
• Equity ownership or compensation tied to research results

Significant Financial Interest (SFI)

A Significant Financial Interest (SFI) generally includes financial interests that reasonably appear related to an investigator’s institutional responsibilities, such as:

• Compensation or consulting income from external entities
• Equity interests or ownership in companies
• Intellectual property rights and income
• Sponsored or reimbursed travel (as defined by sponsor regulations)

Specific thresholds and exclusions are defined in UT Policy GE0002 and applicable sponsor regulations.

Conflict of Commitment (COC)

A Conflict of Commitment occurs when outside activities interfere with an individual’s ability to meet their university responsibilities or commitments of time and effort.

COC is distinct from financial conflicts of interest but may be reviewed in conjunction with COI disclosures when outside activities overlap with research responsibilities

Common Disclosure Examples 

Disclosure allows UTC to determine whether a conflict exists and, if so, how it can be appropriately managed.

Example 1 — Consulting Relationship

A faculty member receives consulting income from a company that sponsors or may benefit from their research.

• Disclosure Required

The financial relationship may be related to the research and must be reviewed.

Example 2 — Equity Ownership

An investigator owns stock or equity in a startup company whose technology is being evaluated in their research.

• Disclosure Required

Equity interests related to research outcomes may represent a significant financial interest.

Example 3 — Intellectual Property

An investigator receives royalty income from intellectual property that is related to their sponsored research project.

• Disclosure Required

Intellectual property interests connected to research outcomes must be disclosed.

Example 4 — Sponsored or Reimbursed Travel

An investigator receives sponsored travel from an external entity related to their research area.

• Disclosure May Be Required

Certain sponsored or reimbursed travel must be disclosed depending on sponsor requirements.

Who must disclose? 

• Faculty investigators
• Senior/key personnel on sponsored projects
• Research staff and postdoctoral researchers
• Graduate student researchers
• Any individual identified as an investigator under sponsor requirements

Investigators must also disclose the significant financial interests of their spouse and dependent children.

When do I need to disclose

Investigators must submit or update disclosures:

• Within 30 days of employment start date
• Prior to proposal submission or participation in sponsored research
• At award intake
• At least annually
• Within 30 days of engaging in a new outside activity
• When project roles or responsibilities change
• When requested by the Office of Research Integrity (ORI)
• Within 30 days of each occurrence of reimbursed or sponsored travel

If unsure whether disclosure is required, investigators are encouraged to disclose. ORI will determine whether a conflict exists.

Management of Conflicts

When a research conflict of interest is identified, UTC may implement a management plan that may include:

• Disclosure of the conflict in publications or presentations
• Modification of research roles or responsibilities
• Independent monitoring or oversight
• Reduction or elimination of the financial interest
• Other measures appropriate to protect research integrity

Management plans are designed to allow research to proceed while maintaining transparency and objectivity.

Enforcement

Failure to disclose required financial interests or comply with management plans may result in corrective action consistent with university policy and sponsor requirements.

Regulatory Authority 

• 42 CFR Part 50 Subpart F (NIH Financial Conflict of Interest Regulation)
• 45 CFR Part 94 (Public Health Service FCOI Regulation)
• NSF Proposal & Award Policies and Procedures Guide
• UT Policy GE0002 – Conflicts of Interest and Commitment

How RCOI Fits Within Research Integrity at UTC 

Research Conflicts of Interest is one component of UTC’s broader research integrity and research compliance framework. These programs work together to ensure research is conducted ethically, safely, securely, and in accordance with federal and institutional requirements.

UTC’s research integrity framework includes:

• Research Conflicts of Interest (RCOI) — disclosure and management of financial and personal interests that may affect research objectivity
• Responsible & Ethical Conduct of Research (RECR) — education and training in ethical research practices
• Research Misconduct — policies and procedures addressing fabrication, falsification, and plagiarism
• Institutional Biosafety (IBC) — oversight of biological safety and regulatory compliance
• Human Subjects Protections (IRB) — protection of human research participants
• Institutional Animal Care and Use Committee (IACUC) — humane care and use of animals in research
• Research Security — protection of research from undue foreign influence and compliance with federal research security requirements
• Export Control — compliance with U.S. export regulations governing controlled technologies, data, and materials
• Safe & Harassment-Free Research Environment — ensuring professional and respectful research environments

This integrated approach ensures that research at UTC is conducted responsibly while supporting collaboration, innovation, and public trust.

How UTC Protects Research Objectivity 

UTC’s Research Conflicts of Interest program:

• Supports investigator engagement with industry and innovation
• Promotes transparency through disclosure
• Ensures compliance with federal and state sponsor requirements
• Protects students, participants, and research outcomes from bias

PHS-Funded Research

Investigators must complete FCOI training before engaging in PHS-funded research and at least every four years thereafter.

Prior to expending funds on a PHS-funded project, UTC will respond in writing within five business days to any request for information about a significant financial interest held by senior/key personnel that UTC has determined to be a financial conflict of interest related to that research. Requests may be directed to the Office of Research Integrity.