An Example of Institutional COI Is
Institutional COI occurs when a company or organization does business with its customers, and that contact introduces the possibility of a conflict of interest for the company. Institutional COI also arises when a person or organization has private interests (such as investments) that may interfere with their ability to be objective in carrying out their public duties (such as teaching).
A typical example of institutional COI is in corporate law departments. Often, such departments provide services to companies in which they invest. The law department may also be interested in the outcome of particular legal cases. For example, when a law firm represents a corporate client in a merger or acquisition, it is not just the lawyers who may have conflicting interests; it is “the law firm” itself.
In the private sector, institutional COI can be prevented by establishing a clear division between providing goods and services to one’s organization and providing goods and services to others. Institutional COI can also be prevented by avoiding conflicts of personal interest (for example, through rigid separation of an individual’s private assets from their public duties) or by instituting internal mechanisms for handling potential conflicts of interest (for example, requiring an impartial decision-maker).
Institutional COI can be prevented in the public sector by setting up external controls that separate decision-makers from the parties whose interests are adjudicated. For example, members of a regulatory agency might receive their paychecks from the government, so they are not beholden to any particular industry. In addition, they might not be permitted to accept bribes or other illegal inducements.
The definition of an institutional COI is comprehensive and can include a variety of financial interests, such as investments, royalties, gifts, and board memberships. For example, a university could have intellectual property and investments that it owns or controls or may receive research funding from a company that sponsors its research. In addition, individual financial donors can also be included.
In some cases, however, institutional COI cannot be eliminated. There might be no way to opt out of an investment without incurring a financial loss; compensation can only sometimes be set at a level that eliminates the influence of outside money on decision-making. A school’s curriculum may demand engagement with the broader community, making it impossible to completely isolate oneself from the forces of the wider world.
Institutional COI can be described as a “conflict of interest,” although it is not the same as a conflict of interest. A conflict of interest (COI) occurs when a person or organization does business with their customers and that contact introduces a financial incentive for them to misbehave. For example, institutional COI can occur when an elected official tries to influence her department’s decision-making process or when a professor tries to force their students to take controversial political or religious positions.
Financial Gain
Financial gain is a type of institutional COI that has recently been changed. Three years ago, financial gain was not considered institutional COI. As of last year, it is considered institutional COI. This supplement to the “no financial gain” section of the rules for what institutional COI makes it only one of two types of institutional COI that wasn’t recognized three years ago and now is. The other type that wasn’t recognized back then but now is: “independence.” Three years ago, independence was not considered a type of institutional COI. Now it’s one that’s recognized as a type of institutional COI.
Financial gain can be used negatively or positively. It can be used to tell a story of wrongdoing. However, it is not the same thing as ‘intellectual independence. Financial gain is not institutional COI; independence is institutional COI.
Financial gain is not the same thing as intellectual independence in and of itself. An economic analysis from an institution may rely on very educated guesses and assumptions, which are necessary to answer some crucial questions: What will the future hold? How can we prepare for that future? But assuming that financial gain is never used in any way would be the same as assuming that the existence of any one institution means nothing except self-referential nonsense.
Financial Interests
While not all institutions have implemented an ICOI policy, nearly half have adopted a policy requiring officials to disclose financial interests. In addition to identifying the relevant financial interests, institutions must also review any other activities that could create an Institutional Conflict of Interest. Such activities may include gifts, payments, equity or royalty income, and business relationships with for-profit entities.
To disclose outside financial interests, investigators involved in a sponsored project must submit a Significant Financial Interest Report (SFIR) to the sponsor. This report must be submitted within 30 days of involvement in a sponsored project. It is also required to be submitted by new investigators within 30 days. However, a financial interest does not always mean an investigator has a conflict of interest.
Gifts
An institutional conflict of interest (ICOI) occurs when an institution’s financial interests could influence its decisions. This can occur in many ways. For example, an academic institution may conduct research that may affect the value of a company’s patents or equity position. The institution may also receive gifts from a company to support an endowed chair at the university or develop clinical practice guidelines for a specific medical condition.
Investments
An institutional code is a conflict of interest between an institution’s research and non-research activities. Generally, institutions must separate their research responsibility from other responsibilities. But not all institutions have policies that govern their research activities. This lack of policy is one of the biggest problems. Moreover, it may not cover critical institutional interests.
Royalties
Institutional Conflict of Interest (CoI) may arise when a researcher receives royalties or other financial benefits for using intellectual property. This could be through royalty payments for research or through equity in a company. This type of conflict of interest may also result from a researcher’s other financial interests, such as co-investments.
Acting on Behalf of the Institution
Institutions may form a standing institutional COI Committee or utilize an existing individual COI committee. The goal of a COI committee is to manage and analyze potential conflicts of interest. This is done by reviewing required disclosures and approved outside activities to determine whether the activities create a conflict of interest. Once identified, the committee should recommend ways to eliminate the conflict.
To prevent institutional conflicts of interest, institutions must address them consistently. Financial conflict of interest policies should be in place, and officials of institutions must disclose any financial interests they have. This is necessary to protect the objectivity of research and the safety and integrity of human subjects.
An institution may also have a financial interest in a particular research study. This can arise in several ways, including when the research involves a relative. This could be a spouse, parent, brother or sister, or another family member. In addition, the research can be sponsored by an organization with a financial stake in the findings.
Institutional COIs are not illegal but are subject to review by the ICOIC, which has the authority to decide their removal. The EVC can also issue directives to the ICOIC to address potential institutional conflicts. During the review process, the ICOIC will identify potential conflicts of interest and recommend ways to eliminate them. In addition, the committee meets annually to determine whether any institutional conflicts of interest have persisted and whether a plan needs to be revised or reissued.
