Financial Conflict of Interest Disclosure

Overview 

The University of Kentucky along with UK HealthCare has an obligation to the public to conduct its activities transparently and with integrity.  Both entities are committed to avoiding financial conflicts of interest that may compromise or appear to compromise the integrity and objectivity of research and the safety of human research subjects.  Because the University encourages its members to engage in outside activities and relationships that enhance its missions, real or perceived conflicts of interest may arise. Full disclosure of any possible conflicts is the key to identifying and dealing with financial conflicts.  

All full-time faculty within the College of Medicine are required to participate in conflict of interest disclosure.   

Annual Reporting  

UK HealthCare
All full-time faculty in the College of Medicine must complete a disclosure specific to UK HealthCare.  This disclosure is completed annually.  The requested information includes:

  1. All outside employment and consulting agreements
  2. All professional income from sources other than the University
  3. Relationships with vendors, including research support, vendor boards and advisory boards
  4. Participation in vendor sponsored or supported educational or informational programs
  5. All other relationships with vendors

Extramural Funding
All faculty in the College of Medicine that receive extramural research funding of any kind must complete a financial conflict of interest disclosure.   The disclosure is required annually but must be updated as changes occur.  Disclosures include:

  1. Ownership of any publicly or non-public traded entities
  2. Income from intellectual property
  3. Research conducted on human subjects
  4. Research funded by PHS 

 Begining in 2016, faculty will receive one email containing a link to a questionnaire that will capture the appropriate information for both of the required disclosures.  Distribution of the email will occur in March.  When you receive a disclosure email, you must complete the questionnaire at the link within that email by the deadline.  

 Conflict Management

If a financial conflict is reported at either disclosure point, a management plan will be requested by an institutional official.  The Management Plan will be reviewed by the Research Conflict of Interest Committee (RCOIC) or by the UK HealthCare Conflict Committee or both.  After reviewing the management plan, the committees have several options:

  1. Accept the management plan as submitted
  2. Amend the plan to decrease the chance for conflict
  3. Require changes to eliminate the conflict.  Examples of required changes include
    1. Removal from participation in the research project
    2. Divestiture of the financial interest
    3. Termination of relationship that creates the conflict

 References

UK HealthCare Policy A01-015 Code of Conduct Addendum
AR 7:2 Financial Conflicts of Interest in Research