Conflict of Interest & Conflict of Commitment

The Conflict of Interest & Commitment Office of VPDoR helps the Stanford research community navigate policies around potential conflict risks, understand the impact of divergent interests, and work with stakeholders to meet the requirements of disclosure and management. Conflicts of interest are common and practically unavoidable in any modern research university. The goal of Stanford’s policies in this area is to reduce the adverse risk of these potential conflicts. In a research university setting, conflicts can compromise — or be perceived as compromising —  academic values, research integrity, and the university mission. 

All faculty members are expected to conduct their affairs in ways that do not compromise the integrity of the university or its public trust. There are times, however, when they face potential conflicts of interest, time commitment or both. Such situations do not necessarily imply wrongdoing or inappropriate activities.

Stanford’s Policy on Conflicts of Commitment and Interest describes the potential conflict risks regarding consulting and other professional activities. It also details the requirements for how faculty, staff, and others must address these risks through disclosure, and provides information about how Stanford reviews and assesses personal financial interests related to the university responsibilities of faculty. More information may be found in the Research Policy Handbook.

Services

Stanford provides two web-based applications to facilitate the disclosure and management of potential conflicts of commitment and interest. One is the Outside Professional Activities Certification System (OPACS). The other is the PHS Travel Report module available to report travel reimbursed through Public Health Services funding including the NIH. 

Pre-Approval of Outside Professional Involvement

As of Sept. 1, 2023, Stanford faculty and research personnel can seek prior approval of outside professional activities through OPACS. Use of this secure site aims to enhance, streamline, and document the process of obtaining prior approval for certain outside professional activities following Stanford's Policy on Conflict of Interest and Conflict of Commitment (COIC).

A sampling of activities that require prior approval include certain employment and appointments outside of Stanford; formation or acquisition of a new entity where ownership interest is 5% or more, or the entity licenses Stanford intellectual property, certain services on boards outside of Stanford, and consulting activities. Learn more details of what activities require disclosure and get more information on OPACS through this FAQ. All activities that were disclosed and received approval before then, do not need to be resubmitted.

Annual Disclosure Requirements

Annually, all Stanford faculty, as well as senior and key personnel on submitted proposals or funded awards, are required to certify their understanding of and compliance with Stanford’s policy. Faculty can use the secure web-based OPACS tool to file these annual certifications and to disclose their outside professional activities.

Transactional Disclosures

In addition, whenever potential conflicts arise, individuals must submit a transactional disclosure. Transactional conflicts of interest can be triggered by any of the following:

• Technology licensing arrangements or other industrial contracts including Material Transfer Agreements
• The filing of a protocol for the protection of humans, stem cells, or laboratory animals in research
• The submission of a proposal or contract to a research sponsor
• The acceptance of gifts
• Certain procurement activities

Researchers receiving Public Health Services funding through the U.S. Department of Health and Human Services can file their required travel disclosures through the PHS Travel Report site. Researchers must disclose reimbursed or sponsored travel related to institutional responsibilities at Stanford regardless of the relationship of the travel to PHS funding when the amount in total or particular entity exceeds $5,000 during the preceding 12 months. The travel report provides more details on the requirements.

Conflict of Interest Officers by School

Requirements and policies often differ depending on the type of research engagement. COI officers are available as resources throughout the Stanford campus. Find the COI officer for your school or department in this list.

Policies & Resources

Policies

• Research Policy Handbook - 4.1 - Policy on Conflict of Interest and Conflict of Commitment
• Research Policy Handbook - 4.2 - PHS and NSF Requirements Regarding Financial Disclosures and Agency Notifications
• Research Policy Handbook - 4.3 - Consulting and Other Outside Professional Activities by Members of the Academic Council and University Medical Line Faculty
• Research Policy Handbook - 9.1 - Inventions, Patents, and Licensing
• Research Policy Handbook - 9.2 - Copyright Policy
• Research Policy Handbook - 9.3 - Administration of Copyright Policy
• Research Policy Handbook - 9.4 - Tangible Research Property
• Research Policy Handbook - 9.5 - Other Intellectual Property: Trademarks, Patents and Proprietary Information
• Research Policy Handbook - 10.6 - Relationships Between Students (Including Postdoctoral Scholars) and Outside Entities

Resources

• COI: Training and Other Information
• COI: Contacts List by School
• Disclosing External Agreements - NIH
• Best Practices for Startups at Stanford

More about Conflict of Interest

Conflicts of interest often arise at the intersection of two fundamental missions: to push the boundaries of knowledge and to transfer that knowledge to the private sector for the benefit of the public. There may be, for example, significant personal financial incentives related to outside consulting, patenting and licensing an invention or being involved with a startup or other outside company. Such situations do not imply wrongdoing or inappropriate activities.

Considerations of personal financial gain, however, must not influence the decisions or actions of individuals in carrying out their university responsibilities. The perception that such incentives might harm research objectivity, the protection of human subjects, or adversely affect other institutional responsibilities in the areas of education, clinical care, or administrative activities is enough to mandate that such conflicts be identified and eliminated, mitigated, or managed. 

More about Conflict of Commitment

Stanford faculty members owe their primary professional allegiance to the university, and their primary commitment of time and intellectual energies should be to the education, research, and scholarship programs of the institution. The specific responsibilities and professional activities that constitute an appropriate and primary commitment will differ across schools and departments, but they should be based on a general understanding between the faculty member and their department chair and school dean. Even with such understandings in place, balancing university responsibilities with external activities — such as consulting, public service, or pro bono work — can result in conflicts regarding the allocation of time and energies. 

Whenever an individual's outside professional activities as defined by Stanford’s Policy on Consulting and Other Outside Professional Activities exceed the permitted limits - typically 13 days per quarter - or whenever a full-time faculty member's primary professional loyalty is not to Stanford, a conflict of commitment likely exists. As part of its policy, for example, Stanford prohibits the direction of a program of research or scholarship at another institution that could be conducted appropriately at Stanford. This includes serving as a Principal Investigator elsewhere. When in doubt, faculty should discuss the situation with their department chair, school dean, or VPDoR.