Procedures for Declaring Potential Conflicts of Interest and Obtaining Approval for Management Plan

1. Determine if you have a potential conflict of interest by reviewing these guidelines and the relevant sections of The University of Texas Handbook of Operating Procedures:
   
   http://www.utexas.edu/policies/hoppm/h0511.html#h0511a or http://www.utexas.edu/research/osp/osp_handbook.html#coi.
   
   If you have questions regarding the policy, please contact your associate dean for research and/or the associate vice president for research (232-2654). You may also want to review The University of Texas System Ethics Policy, Attachment One to HOP Sec. 5.11, Regents' Rules, Part One, Chapter III, Section 4.
   
   You may also want to review The University of Texas at Austin Institutional Review Board (IRB) policies and procedures regarding conflicts of interest, Section 3.7.
   
   
2. Declare a potential conflict of interest by completing the form, The University Of Texas at Austin Financial Disclosure and Conflict Of Interest Report [Word]. Paper copies can be obtained from the Office of Sponsored Projects (OSP) or the Office of Technology Licensing (OTL). Submit the form to OSP at the time of submitting the research proposal (if applicable) or to the OTL if a license agreement is involved. The materials will be forwarded to the Office of the Vice President for Research, along with a copy of the proposal, research agreement, and/or license agreement, if applicable.
   
   
3. Develop a Potential Conflict of Interest Management Plan in cooperation with the associate vice president for research responsible for the university’s conflict of interest policy. Refer to the example management plan attached. Also refer to: http://www.utsystem.edu/ogc/intellectualproperty/conflict.htm.
   
   
4. Forward the Management Plan to the Office of the Vice President for Research. If the research is externally funded, a meeting of The University’s Objectivity in Research (OIR) Committee will review the proposed management plan.
   
   
5. Once the Management Plan has been approved by the OIR Committee, you will be asked to write a letter of certification to the Vice President for Research indicating that you accept the management plan and agree to abide by it. See: D2, Procedure for Obtaining Approval of Plan to Manage Conflicts of Interest.
   
   
6. The chairperson of the OIR Committee will prepare the institutional certification letter that will accompany the employee certification letter and management plan to the Executive Vice Chancellor for Academic Affairs. For an example of the institutional letter that will be prepared, see: Submitting a Plan to Manage Conflict of Interest to U.T. System for Approval.
   
   
7. Once the Executive Vice Chancellor for Academic Affairs has approved the plan, the documents — management plan, employee certification letter, institutional certification letter — will be prepared by the Office of the Vice President for Research for placing on the Institutional Docket of the next Board of Regents’ meeting. (Meetings are held on May 10, August 10, November 10, and February 10. UT Austin internal deadline is 6 weeks prior to the Board meeting.)
   
   
8. Each such financial disclosure statement must be updated during the period of the research grant or contract on an annual basis, or more often if any new reportable Significant Financial Interests are obtained.
   
   
9. In addition, even if the researcher has no reportable Significant Financial Interests at the time a proposal is written/submitted and/or a grant or contract is awarded, he or she has the obligation to complete a financial disclosure statement if any reportable Significant Financial Interests are subsequently obtained.