Conflicts of Interest Resources and Links

Government Regulation and Guidance

NACUA Outlines

Journal of College and University Law Articles

NACUA Publications

Resource Pages

Institutional Policies

Media Coverage

Other Documents

Government Regulation and Guidance

OIG Report on NIH Grantee Management of Financial Conflicts of Interest
(November 18, 2009)

NIH: Notice of Proposed Rulemaking re Conflicts of Interest
(May 8, 2009)

HHS Inspector General Report on Conflicts of Interest in Extramural Research
(January 22, 2008)

HHS: Research--Guidance for Human Subjects Protection
(May 12, 2004)
Complete text of final guidance entitled "Finacial Relationships and Interests in Research Involving Human Subjects: Guidance for Human Subject Protection" issued by the Office of Public Health and Science (OPHS), U.S. Department of Health and Human Services (HHS), and published in the May 12 Federal Register.

Financial Relationships and Interests in Research Involving Human Subject: Guidance for Human Subject Protection
Summary: Extracted Pages. 26393 Federal Register /Vol. 69, No. 92 /Wednesday, May 12, 2004

GAO: Financial Conflicts of Interest in University Research
(November 19, 2003)

GAO: Financial Conflicts of Interest in Biomedical Research
(November 2001)

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NACUA Outlines

Compliance in Conflict of Interest Policies (Robert Bienstock, Laure Ergin, Barcardi Jackson; November 2009 CLE Workshop)

Potential Civil and Criminal Consequences of Conflicts of Interest (Benjamin Rosenberg, November 2009 CLE Workshop)

Lenders, Vendors and Conflicts of Interest (Joseph E. Oliva, June 2008 Annual Conference)

Developing and Managing Conflict of Interest Policies (Dennis H. Blumer and Kristine J. Dunne, NACUA 2008 Annual Conference)

Conflict of Interest and Conflict of Commitment in Employment: Teaching (Christopher L. Ashley, NACUA March 2008 CLE)

Conflict of Interest and Conflict of Commitment in Employment: Entrepreneurship (Frederick G. Savage, NACUA March 2008 CLE)

The Enron Effect: Accountability in Higher Education Governance and Business Practices: Examples of Policies and Procedures that Further a “Control Environment” (Tobey Oxholm, NACUA 2007 Annual Conference)

State Ethics Reform and Its Impact on Public Universities (Elizabeth Minott, NACUA April 2007 CLE Workshop)

Federal Exempt Organizations Reform: Responding to Sarbanes-Oxley (Dorothy K. Robinson; NACUA 2006 Annual Conference)

College and University Codes of Conduct (Stephen J. Hirschfeld, NACUA March 2006 CLE Workshop)

The University Becoming A Shareholder: Negotiating Equity Licenses (Kathryn A. Donohue Drexel University Philadelphia, Pennsylvania Christopher F. Wright McCausland, NACUA November 2004 CLE Workshop)

Making and Modifying Policy on Campus: The "When and Why" of Policy Making (Kathryn Bender, NACUA 2004 Annual Conference)

Faculty Employment Outside the University: Problems and Policies (John Biancamano, NACUA March 2004 CLE Workshop)

Faculty Employment Outside of the University: Conflicts of Commitment (Donna Euben, NACUA March 2004 CLE Workshop)

Directing and Managing Conflicts of Interest in Sponsored Research (Jeanine Ardent Ornt, NACUA November 2002 CLE Workshop)

Detecting and Managing Conflicts of Interest in Sponsored Research: Varieties of Conflicts (Joan Leonard, NACUA November 2002 CLE Workshop)

Academic Institutional Policies and Practices for Taking Equity in Faculty Start-Ups (Carol T. Carr, NACUA 2002 Annual Conference)

Institutional Conflicts of Interest (Susan Ehringhaus, NACUA 2002 Annual Conference)

The Entrepreneurial Professoriate: Faculty Start-Ups and Other Entrepreneurial Activity for the Employment Lawyer - Special Considerations in Dealing with Faculty Start-Up Companies (Barbara Wingo, NACUA March 2002 CLE Workshop)

Six Tips for Managing Entrepreneurial Faculty (John Biancamano, NACUA March 2002 CLE Workshop)

Financial Conflicts of Interest in Research: An Academic Perspective (Julie Gottlieb, NACUA 2001 Annual Conference)

Faculty Start-Ups: The Tangled Web (Susan Carney, NACUA 2001 Annual Conference)

Dealing with Faculty Owned Start-Up Companies: A Policy Development Checklist (John Biancamano, NACUA 2001 Annual Conference)

The Use of Affiliated Entities by Private Universities: Challenges and Opportunities in Governance, Conflicts of Interest, and Liability Limitation (James Carolan, NACUA 2000 Annual Conference)

Faculty and Staff Outside Activities (Patricia Friend, NACUA November 1999 CLE Workshop)

The University Research Enterprise: Technology Transfer, Faculty Start-Ups, and Conflict of Interest (Kathleen S. Irwin Mark Doremus University of Wisconsin-Madison, NACUA November 1998 CLE Workshop)

Financial Relationships with Commercial Entities: Enforcement Exposures and Preventive Measures (Stephen Immelt and Elizabeth Barry, NACUA 1998 Annual Conference)

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Journal of College and University Law Articles

Sarbanes-Oxley in Higher Education: Bringing Corporate America's "Best Practices" to Academia (Tobey Oxholm, 2005)

University Controlled or Owned Technology: The State of Commercialization and Recommendations (Mark L. Gordon, Volume 30, No. 3, 2004)

Faculty Conflicts of Interest in an Age of Academic Entrepreneurialism: An Analysis of the Problem, the Law, and Selected University Policies (Peter Harrington, Spring 2001)

Minimum Compliance with Minimum Standards: Managing Trustee Conflicts of Interest (David Harpool, Winter 1998)

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NACUA Publications

Managing Financial Conflicts of Interest in Human Subjects Research (Lance Shea, Frederick Robinson, and Lara Parkin)

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Resource Pages

Preferred Lender Program Investigations and Practices - Resources and Links

Corporate Responsibility Resources and Links

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Institutional Policies

American University Conflict of Interest Policy

Boston University Conflict of Interest Policy

Carnegie Mellon University Policy on Conflicts of Interest and Commitment

Catholic University Board of Trustees Conflict of Interest Policy

Drexel University Policies

• Annual Conflict of Interest and Disclosure Process (Trustees)


• Reaffirmation of Procurement Policy Statement; Reaffirmation of Investment; Policy and Procedure: Procurement Policy Statement and Guidelines


• Resolution to Establish a Captial Projects Review and Approval Policy; Capital Projects and Review Policy


• Contract Protocol Policy


• Code of Ethics for Senior Financial Executives


• Code of Ethical Principles and Standards of Professional Practice for Office of Institutional Advancement


• Policy of Reporting and Investigating Allegations

Duke University Conflict of Interest Policy (faculty)

The George Washington University Conflict of Interest Policy (Non-Faculty Employees)

Georgia State University Conflict of Interest Policy

Harvard University Policy on Conflicts of Interest and Commitment

Indiana University Policy on Conflicts of Interest (Staff)

Johns Hopkins University Policy on Conflicts of Interest and Commitment

Johns Hopkins University Statement of Ethical Standards

Northwestern University Conflicts of Interest Policy and Forms

Oakland University Conflict of Interest Policy

Penn State University Purchasing Conflict of Interest Policy

Stanford University Conflict of Interest and Commitment Policy (Academic Staff)

Stanford University Policy on Institutional Conflict of Interest (Research)

Tulane University Conflicts of Interest Policy

University of Alabama-Birmingham Conflicts of Interest Policy

University of California Policy on Conflict of Interest and Specialized University Policies, Guidelines and Regulations Related to Conflict of Interest

University of Chicago Conflicts of Interest Policy

University of Colorado Policy on Conflicts of Interest and Commitment

University of Kansas Medical Center Policy on Institutional Conflict of Interest

University of Michigan By-Laws and Policies on Conflict of Interest and Commitment

University of Michigan Business and Finance Conflict of Interest Policy

University of Minnesota

• Board of Regents Policy: Individual Business or Financial Conflict of Interest (COI)


• Implementing the Individual Business or Financial COI Regents Policy


• Disclosing Potential Individual COI


• Evaluating and Managing Individual COI Disclosures


• Avoiding COIs in Special Situations


• Board of Regents Policy: Institutional Conflict of Interest (ICOI)


• Managing Potential Institutional Conflicts of Interest


• Managing Potential ICOI - Gifts


• Managing Potential ICOI - Investments


• Managing Potential ICOI - Licensing & Tech Transfer


• Managing Potential ICOI - Purchasing


• Managing Potential ICOI - Special Considerations for Human Subjects


• Managing Potential ICOI: Disclosures Disclosures by University Officials & Other Individuals


• Board of Regents Policy: Outside Consulting and Other Commitments


• Outside Consulting and Other Commitments


• Outside Consulting and Other Commitments by Faculty and Academic Professional and Administrative (P&A) Staff


• Outside Consulting and Commitments by Intercollegiate Athletics Staff


• Board of Regents Policy: Code of Ethics for Members of the Board of Regents

University of Missouri Conflict of Interest Policy

University of New Mexico Conflicts of Interest Policy

University of the Pacific Conflict of Interest Policy for Regents and Institutional Officers

University of Pennsylvania Policy on Conflict of Interest (Faculty)

University of Rochester Policy on Institutional Conflicts of Interest in Research Activities

University of Tennessee Conflict of Interest Policy for Trustees

University of Texas at Austin Policy on Institutional Conflicts of Interest in Human Subjects Research

University of Virginia Policy on Conflicts of Interest

Vanderbilt University Conflicts of Interest Policy

Washington University Conflicts of Interest Policy

Washington and Lee University Policy on Conflicts of Interest for Officers, Administrators and Finance Personnel

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Media Coverage

July 29, 2008 New Ethics Rules for Admissions Consultants (InsideHigherEd.com)

July 9, 2008 Accepting More Federal Oversight (InsideHigherEd.com)

July 9, 2008 Getting Back to Basics (InsideHigherEd.com)

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Other Documents

AGB Statement on Conflict of Interest (December, 2009)

Admissions Group to Tackle Conflict of Interest Issues / InsideHigherEd.com
(March 10, 2008)

Slow Progress on Institutional Conflicts Policies / InsideHigherEd.com
(February 13, 2008)

Governance: Principles for Good Governance and Ethical Practice
(October 2007)
Complete text (32 pages) of publication issued by the Panel on the Non-Profit Sector. Subtitled "A Guide for Charities and Foundations", the publication describes 33 principles of sound practice for consideration by non-profit and charitable organizations, organized into four categories: Legal Compliance and Public Disclosure; Effective Governance; Financial Oversight; and Responsible Fundraising.

Governance: Report to the Board of Regents of the Smithsonian Institution
(June 2007)
Complete text (112 pages) of report issued by the Independent Review Committee (IRC) to the Board of Regents of the Smithsonian Institution. The IRC was charged with conducting an independent examination of the compensation and expenses of the Smithsonian's Secretary as well as certain governance practices. The report summarizes the committee's findings and recommendations, encompassing executive compensation and expenses, board oversight, and the role of counsel and auditors.

Governance: IRS Proposed Suggestions for Tax-Exempt Organizations
(February 2007)
Complete text (4 pages) of document entitled “Good Governance Practices for 501(c)(3) Organizations issued by the Internal Revenue Service (IRS) on February 2, 2007. In order to ensure that directors understand their roles and responsibilities and promote good governance practices, the IRS suggests that tax-exempt organizations review and consider: adoption of a mission statement; adoption of codes of ethics and whistleblower policies; director duties of loyalty and due diligence and oversight of conflicts of interest; public transparency of activities and finances; adoption of fundraising policies; board oversight of finances; compensation of directors, officers and staff; and adoption of a document retention policy.

AAMC: Research Conflict of Interest Policy Survey
(September 15, 2004)

AAMC: Protecting Subjects, Preserving Trust, Promoting Progress II
Summary: October 2002 Protecting Subjects, Preserving Trust, Promoting Progress II: Principles and Recommendations for Oversight of an Institution's Financial Interests in Human Subjects Research Task Force on Financial Conflicts of Interest in Clinical Research

AAMC: Report of Task Force on Financial Conflicts of Interest in University Research (October 2002)

AAMC: Protecting Subjects, Preserving Trust, Promoting Progress: Policy and Guidelines for the Oversight of Individual Financial Interests in Human Subjects Research / AAMC (Association of American Medical Colleges)
(December 2001)

AAU Report on Individual and Institutional Conflicts of Interest
(October 2001)

ACE: Working Paper on Confilct of Interest

Council On Governmental Relations (COGR): Approaches to Developing an Institutional Conflict of Interest Policy

NACUBO Code of Ethics (for Business Officers)

Study Abroad: FEA Code of Ethics
Complete text (17 pages) of document entitled "Code of Ethics for Education Abroad" released by the Forum on Education Abroad. The document includes sections devoted to truthfulness and transparency, responsibility to students, relationships with host societies, observance of law and good practice, conflicts of interest, and gifts, gratuities, discounts, rebates and compensation.

Conflict of Interest: Report of AAMC-AAU Advisory Committee
Complete text (87 pages) of report and recommendations issued by a joint Association of American Medical Colleges (AAMC) and Association of American Universities (AAU) Advisory Committee on Financial Conflicts of Interest in Human Subjects Research. The report includes chapters on individual conflict of interest policies, institutional conflict of interest policies and implementation of conflict of interest policies, as well as a model institutional conflicts of interest.



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NACUA Clearinghouse of Training Materials for the Practice of Preventive Law in Higher Education.