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The Office of Institutional Compliance

Conflicts of Interest/Conflicts of Commitment

Numerous regulations, laws, and policies provide guidance regarding 1) employees' participation in outside activities and the holding of financial interests in outside entities; 2) employees' disclosures of such activities and interests; 3) how UTHealth must gather and review this information; and 4) how UTHealth works with employees and supervisors to manage, reduce, or eliminate identified conflicts of interest and conflicts of commitment. While UTHealth recognizes the benefits that may be realized by employees sharing expertise and interacting with other organizations and industry, where such interactions would advance scientific knowledge in the public interest, all employees must proactively avoid situations that give even the appearance of affecting one's UTHealth's job duties and responsibilities.

What are the Conflict of Interest Policies?

Applicable policies include: UTHealth's Conflict of Interest, Conflict of Commitment and Outside Activities Policy (HOOP 20) and UTHealth's Institutional Conflict of Interest Policy (HOOP 221) and The University of Texas System Systemwide Policy (UTS 180).

What are the two types of conflicts?

Conflicts can be real, or they can be perceived (only giving the appearance of a conflict).  Either may raise concerns by the public, research sponsors, funding agencies, or donors.  There are two types of conflicts that have the potential to adversely affect, or appear to affect, how you perform your job responsibilities:  conflicts of interest and conflicts of commitment.

What is conflict of interest?

Conflict of interest is an outside activity or financial interest (or your family member’s activity or interest) that could directly or significantly affect the performance of your UTHealth responsibilities, with the potential to: 1) influence, or even appear to influence, your conduct or decisions in your job; 2) impair your independence of judgment in your job; and 3) induce you to inappropriately disclose confidential or proprietary information that you have obtained in your job.  Conflicts of interest are generally issues of financial or personal gain. Please refer to the Review for Potential Conflicts - Checklist to help determine if a proposed outside activity might create a conflict of interest or conflict of commitment.

What is conflict of commitment?

Conflict of commitment is devoting time or effort to an outside activity that interferes with the fulfillment of your UTHealth job responsibilities, or using state-owned resources (computers, e-mail, supplies, equipment, personnel, laboratory or administrative space, etc.) without approval in connection with your personal outside employment, board service, or other outside activity. Conflicts of commitment are generally issues of time and resources.Please refer to the Review for Potential Conflicts - Checklist to help determine if a proposed outside activity might create a conflict of interest or conflict of commitment.

What should I consider in my interactions with industry?

Refer to the Clinician Relationships with Industry for an overview of the standards of conduct expected for clinicians (and employees in clinical departments) in their university relationships with for-profit companies that develop, market, and sell goods or services related to patient care activities.  The guidance also serves as a "best practice" guide for employees in other fields in their university relationships with vendors.

How are conflicts reviewed and managed?

Reviews performed of potential conflicts will be conducted by the employee's supervisor or other department or School official, with the assistance of the Conflicts of Interest Office and the Conflict of Interest Committees (Institutional and/or Research) and will consider: 1) the employee's UTHealth job duties and responsibilities; 2) the nature of the employer's relationship with the outside entity; 3) the amount of compensation to be received; 4) the value of any financial interest; and 5) the potential influence the relationship may have, or appear to have, on the employee's UTHealth academic, research, clinical, professional, and/or administrative responsibilities.

What is the Sunshine Act (Open Payments)?

Per the Centers for Medicare and Medicaid Services (CMS.gov) website, "Open Payments is a national disclosure program that promotes a more transparent and accountable health care system by making the financial relationships between applicable manufacturers and group purchasing organizations (GPOs) and health care providers (physicians and teaching hospitals) available to the public. Learn more about Open Payments."

Who can I contact for questions about conflict of interest or conflict of commitment?

If you have questions, please contact the Conflict of Interest Office.