The Research Integrity team, in partnership with the Conflict of Interest Review Board:

• reviews all Conflict of Interest Reporting Forms that are submitted through the University's electronic conflict of interest disclosure system;
• conducts a conflict of interest review for any investigator on a research project that is administered through Brown;
• conducts a conflict of interest review of related financial interests identified via a protocol submission to the Institutional Review Board and provides a recommendation to the board regarding disclosures to human research participants; and
• refers conflict of interest cases that are unrelated to research and conflicts of commitment to the appropriate dean's office.

When reviewing interests, the Research Integrity team and Conflict of Interest Review Board look at a number of factors, such as the type and magnitude of the financial interest, the degree of overlap between the outside interest and University responsibilities, and whether the interest could affect the research or educational activity. Perception is considered in the analysis.

The Conflict of Interest Review Board meets monthly during the academic year to identify financial conflicts of interests with research, teaching and other scholarly activities. The board makes recommendations to the vice president for research regarding the elimination, reduction or management of identified financial conflicts of interests and monitors implementation of any management plan. The Conflict of Interest Review Board comprises faculty from a broad range of departments.

Having a conflict of interest does not prohibit you from engaging in research or other scholarly activities. In most instances, a conflict of interest can be appropriately managed so that you can, for example, continue to participate in a research activity while keeping your financial or outside interest. In some rare instances the conflict may be such that it cannot be appropriately managed. In such a case, you may be asked to consider reducing or eliminating the financial interest rather than discontinue your participation in the research activity. In general, your outside activities and interests should not prevent you from carrying out your research activities, teaching and other University duties and responsibilities.

Managing Financial Conflict of Interest

In cases where the Conflict of Interest Review Board recommends that the financial conflict of interest be managed, the Research Integrity team, with guidance from the board and the vice president for research, develops and implements a financial conflict of interest management plan. The management plan lists required and recommended management measures that are designed to mitigate the conflict of interest and reduce the potential for bias to affect the design, conduct or reporting of the research. 

Possible measures include but are not limited to:

• disclosure of the financial interest in publications/presentations;
• disclosure of the financial interest to all collaborators on the research project;
• disclosure of the financial interest to students/trainees;
• disclosure to any study participants, if applicable.

The management plan is signed by the investigator and is subject to annual review and/or periodic audits.

Disclosing Managed Conflicts

Managed conflicts should be disclosed in any relevant setting, including:

• to any student, trainee or junior faculty you supervise;
• in any publication and presentation that is related to the financial interest or conflict of interest; and
• to board or committee members if it is relevant to an issue or item that is being discussed by the board/committee. 

In general, it is better to disclose than not to disclose. When disclosing, providing context is critical. Disclosure is an important ethical responsibility and should not be treated as an afterthought. In some instances, providing a written disclosure may be more efficacious than a verbal disclosure.