Why Conflicts of Interest Matter

All faculty, including adjunct faculty and emeritus faculty who are participating in a sponsored (funded) project, are required to file annual conflict of interest (COI) disclosures. Others who must file such disclosures include EHRA professionals paid from any course, graduate assistants paid from ledger 5 (sponsored research) funds, and research personnel engaged in the design, conduct, or reporting of sponsored research (including part-time and temporary employees).

Additional details on who should file a COI disclosure and when it should be filed are available at https://research.ncsu.edu/administration/compliance/research-compliance/coi/coi-procedures-and-guidance/#who-is-required-to-complete-an-annual-coi-disclosure

We are sharing this reminder because the failure to disclose conflicts of interest and conflicts of commitment (through the Notice of Intent [NOI] to Engage in External Professional Activities for Pay (EPAP) system) can lead to criminal penalties. In a recent case at the University of Kansas, a professor was convicted of a felony “for making false statements in the University of Kansas’s conflict of interest and commitment disclosure form.” In this case, the professor failed to disclose their involvement in a talent recruitment program sponsored by the government of the People’s Republic of China.

While a lot of the news about COI/NOI disclosures has focused on China, we remind you that any potential conflict of interest must be reported as called for in the university’s COI system, and you must disclose external activities for pay in the NOI system. Bear in mind that the university’s goal is not to discourage faculty or staff from engaging in permissible external activities. Indeed, the university’s policy on COIs and NOIs states that “the Policy also recognizes the importance of application of knowledge outside the institution and that this function may be enhanced by appropriate relationships between employees and private entities.” Rather, our goal is to make sure that any external activities do not create a conflict of interest that must then be managed by the individual and their department or unit. And we require disclosure of external activities for pay to ensure that individuals do not have an unmanageable conflict of commitment that “interferes with the employee’s duties and responsibilities” at the university. Remember, we require this disclosure to ensure that, when they are permissible, they are manageable, and when they are not permissible, the activities are avoided before a major investment of time and effort is made.

If you have any questions about these matters, please contact me at tabirkla@ncsu.edu or call my office.