There has been a lot of discussions lately in the news and on-campus regarding conflict of commitment (COC) and conflict of interest (COI); what they are and the obligation of CSU employees to report actual, potential, and perceived conflicts.

This article is designed to explain the differences between COC and COI and to describe University requirements for disclosing each.

Conflict of Commitment (COC)

Think of conflict of commitment like a calendar conflict – two things that can’t occur simultaneously. A COC occurs when an employee’s activities outside of their work assignment (whether those activities are paid or unpaid) create a “schedule conflict” or potential conflict, with their employment.

As a CSU employee, our primary commitment of time and intellectual energies should be to our University responsibilities. Most conflicts of commitment involve issues of time allocation. For example, many individuals at CSU are members of professional organizations. At times we may volunteer with those organizations, like serving on a committee or chairing a regional conference.

When the time spent on those outside activities infringes on CSU duties, a conflict of commitment exists.

Additional examples of COC include:

• A faculty member who dedicates more than the permitted one day per week on personal consulting
• Using institution resources in support of outside activities
• Being inaccessible to students, staff, or colleagues during one’s appointment period due to external commitments

If an employee’s outside interactions such as consulting or volunteering interfere with, or could interfere with, their ability to carry out their Institutional obligations, a COC exists and must be managed.

Conflict of Interest (COI)

A conflict of interest exists when a person has two relationships (i.e., interests) that compete or may compete for that person’s loyalties. These interests may be financial or otherwise. For example, if a researcher directs a purchase to a company he/she owns or that is owned by a relative.

Additional examples of COI include:

• Ownership in an entity that supports an investigator’s research or creative activity
• Giving favors to relatives in matters of hiring, promotion, and transfer (i.e., nepotism)
• Self-dealing or self-serving relationships such as accepting gifts or bribes from a vendor in exchange for adopting their product

CSU Policy

Under CSU’s policy, full-time faculty and administrative professionals must make annual disclosures of affiliations and commitments that may involve a conflict of commitment or interest. Annual disclosures are made through the Kuali COI module and should be amended any time a new conflict, real or potential, emerges.

If a conflict is determined, it must be managed through the implementation of a written conflict of interest management plan. If a conflict cannot be managed, the activity will be disallowed.

Financial Conflict of Interest (FCOI)

FCOI is a type of conflict of interest that involves significant financial interest and its impact on funded research. FCOI is when a significant financial interest (SFI) directly affects or could appear to affect the professional judgment of a researcher when designing, conducting, and reporting research.

What is considered an SFI?

A financial interest is anything of monetary value that belongs to an investigator or the investigator’s spouse or dependents. It becomes significant when it meets any of the following definitions:

• Income from or equity (stock, stock options, or other ownership interest) in a publicly-traded entity that, in aggregate, meets or exceeds $5,000 in value in the 12 months prior to disclosure
• Remuneration in aggregate, that meets or exceeds $5,000 in value in the 12 months prior to disclosure
• Remuneration from an outside entity for intellectual property rights and interest (patents, copyrights, royalties, licensing fees) in the 12 months prior to disclosure
• Any travel costs funded (reimbursed or sponsored) by an outside entity during the 12 months prior to disclosure
• Equity interest in a non-publicly traded entity

Who must disclose FCOI?

PHS-funded investigators must confirm the disclosure of all Significant Financial Interests at the time of application for PHS funding. This rule also applies to those agencies that follow the PHS-regulation. At any time during a sponsored project a new or potential conflict arises, it should be disclosed. Non-PHS investigators should refer to their specific sponsoring agency guidance regarding disclosure of SFI and should update their annual disclosures accordingly.

For more on COC and COI disclosure at CSU, refer to:

CSU Faculty Manual, Section D: https://facultycouncil.colostate.edu/faculty-manual-section-d/#D.7.7.4-3

CSU Conflict of Commitment and Consulting Policy: http://policylibrary.colostate.edu/policy.aspx?id=437

CSU Conflict of Interest Policy: http://policylibrary.colostate.edu/policy.aspx?id=615

Research Integrity and Compliance Review Office (RICRO): https://www.research.colostate.edu/ricro/coi/

Resources for International Collaborations: https://www.research.colostate.edu/international-collaborations/