Conflict of Interest and Disclosure Policy of the Jacobs School of Medicine and Biomedical Sciences

Policy Review History: Faculty Council approved—05/27/2026

The Jacobs School of Medicine and Biomedical Sciences (Jacobs School) fosters a diverse community of professionals. They engage both individually and collectively in a range of activities supportive of the mission of the School and are expected to execute these activities in a manner that is free of conflicts of interest that would interfere with their University activities or distort the actual or perceived judgments expected of them due to personal, financial or other interest. Managing conflicts of interest is crucial to maintaining public trust and to ensuring the objectivity of research findings and clinical care. 

In recognition of these issues, the Jacobs School wishes to ensure that no activity of the School is unduly influenced by conflicting interests. This aims to avoid even the perception of abridgment of the implicit trust (which is based both on reality and perception) the public places in us to practice in the best interests of our patients and with the greatest integrity. 

This policy applies to all Jacobs School faculty, administrators and staff, at all locations at which they work, in any capacity, even if a site does not have a similar policy.

This COI Policy is subordinate to the appropriate COI policies of the University and to those of the SUNY Board of Trustees. 

Conflicts of interest involve any situation in which a significant financial or other interest has the potential to influence or appear to influence clinical, educational, service, or research decisions. University policy indicates that conflicts of interest may be financial (involving the potential for financial gain), general (involving personal gain or privileges) or conflicts of commitment (involving obligations, responsibilities or commitments that could interfere with an individual’s primary responsibilities). Potential COI concerns apply directly to members of the Jacobs School of Medicine and Biomedical Sciences community. However, COI concerns may also apply to spouses, domestic partners (or similar relationships), dependent children, and any other family member residing in the same household.

Any of the following within the past year is considered a significant financial interest:

1. Equity interests (e.g., stocks, stock options, warrants, or other ownership interests) greater than $5,000.00 by a faculty member, spouse or dependent child in the manufacturer or sponsor. Income from investment vehicles such as mutual funds and retirement accounts is excluded if the investigator does not control investment decisions made in these vehicles and is unaware of the actual equity interests included in the vehicles.
2. Serving on a paid advisory board or as a paid consultant for a device or pharmaceutical company.
3. Serving as a paid consultant or expert witness in cases involving clinical or investigational products.
4. Paid trustee, director, officer, board member, owner, director or other office in a device or pharmaceutical company.
5. Principal investigator on any industry sponsored study, including investigator initiated industry sponsored studies.
6. Intellectual property rights to any product or device.
7. Any royalty, licensing or other income linked to a product, or the contractual right to future royalties or other proceeds directly or indirectly under a pending or issued patent, license or other property right.
8. Participating in an industry speaker’s bureau.
9. Other payments for services to a pharmaceutical or device company.
10. Potential for financial benefit from an invention or patent owned by or licensed to a pharmaceutical or device company except for patent income paid directly from the University at Buffalo as noted below.
11. Travel reimbursement or sponsorship except for travel that is reimbursed or sponsored by a federal, state, or local government agency, an institution of higher education, an academic teaching hospital, or a research institute that is affiliated with an institution of higher education.

These include:

1. Ownership or investment in an outside business or enterprise
2. Serving as director, officer, partner, consultant or other agent of any outside enterprise
3. Outside professional or other activity 
4. Other Employment

A significant financial interest exists if equity interests (e.g., stocks, stock options, warrants or other ownership interests) by a faculty member, spouse, or dependent child equals or exceeds $5,000 in value in the aggregate over the past year as determined through reference to public prices or other reasonable measures of fair market value or represent more than a 5% ownership interest in a single entity, including non-publicly traded entities. In addition, aggregate remuneration to the faculty member, spouse, domestic partners and/or dependent children from activities listed in section 2.2.1 that equals or exceeds $5,000 from a single entity constitutes a significant financial interest in that entity.  Any intellectual property rights and interests, as well as related royalties, are considered to be significant financial interests except when these are received by current UB faculty from SUNY or the Research Foundation. UB considers any income from foreign entities and sponsored travel to be significant financial interests. A significant obligation includes positions held by a faculty member or immediate family members as an officer, trustee, director, employee or consultant to any outside entity, regardless of whether the position is paid or the entity is for profit or not for profit that could appear to influence responsibilities as a faculty member. When a significant financial interest or obligation has the potential to conflict with research obligations, patient care, or service to the School or to the University, the conflict must be managed or eliminated as described below.

Conflict of interest does not include:

1. Salary, royalties, or other remuneration paid to an investigator by the university (State, Research Foundation, or University at Buffalo Foundation (UBF)), if the investigator is currently employed or otherwise appointed by the university.
2. Intellectual property rights assigned to SUNY or the RF and agreements to share in royalties related to such rights.
3. Income from investment vehicles, such as mutual funds and retirement accounts, as long as the investigator does not directly control the investment decisions made in these vehicles.
4. Income received from U.S. based organizations for seminars, lectures, teaching engagements, or service on advisory committees or review panels sponsored by a federal, state, or local government agency, an institution of higher education, an academic teaching hospital, a medical center, or a research institute that is affiliated with an institution of higher education.

Disclosure of conflicts of interest for funded investigators follows the University’s Investigator Conflict of Interest Policy.

 University policy requires disclosure of significant financial interests and obligations annually, in association with requests for research funding, Institutional Review Board (IRB) submissions and within 30 days of a new significant financial interest. Disclosures must be compliant with UB and NIH conflict of interest policies and procedures, including disclosure of conflicts of interest in public presentations or publications of research results.

In accordance with established norms. Individuals participating in grant sponsored research must report potential conflicts of interest. An annual report should include status of the conflict of interest and any changes in the management plan. The report should include:

1. Name of the entity with which the conflict of interest exists
2. Nature of the conflict of interest (e.g., honorarium, equity, etc.)
3. Value of the financial interest or statement that the value cannot be determined
4. Description of how the financial interest relates to the research
5. Basis for determination that a conflict of interest exists
6. Institutional management plan

A COI that arises during the course of patient care must be disclosed to a patient, when the COI is applicable to the care of that specific patient. 

Conflict of interest information must be made available to any requestor within 5 business days of a request for information. The information will only be released in response to a specific request. The information should include:

1. Investigator’s name, title and role with request to a research project if applicable
2. Name of the entity in which the individual has a financial interest
3. Nature of the conflict of interest
4. Value of the interest or a statement that the value cannot be determined

COIs that arise during the course of education or instruction must be disclosed to learners and audiences promptly during the course of said education or instruction. This disclosure should be provided at the beginning of the educational or instructional session. Generally, it is acceptable to inform the audience at the outset in the event that no COIs are present or relevant to the session.

COIs should be managed, reduced, or eliminated by divestiture of financial interests, modification of the research or clinical care, or public disclosure and monitoring. Disclosure may be sufficient for treatment recommendations to patients, and educational and promotional presentations.  In research and service on formulary committees, additional measures are necessary to resolve or manage conflicts.

The individual receiving report of a conflict should themselves be a disinterested party. If they have a significant interest, then they should recuse themselves from further discussions about the management, reduction, or elimination of the reported conflict. 

It is usually preferable to eliminate potential conflicts of interest by divesting oneself of one or more of the conflicting activities. However, there may be other appropriate mitigation strategies that do not require complete elimination of the conflict or relationship in question. 

A financial conflict of interest may be reduced so that it falls below the threshold that constitutes a significant financial conflict. Remuneration of less than $5,000 annual or equity interests of less than 5 percent are allowable and do not require elimination, further reduction or management.

Conflicts of Interest related to research will be managed by the Senior Associate Dean for Research. Conflicts of interest related to clinical matters, patient care or educational matters will be managed by the applicable Department Chair. The respective Senior Associate Deans or Department Chairs act in collaboration with and on behalf of the Dean.

A plan to manage a conflict of interest must be independently reviewed by the appropriate Senior Associate Dean or Department Chair, as outlined in this policy. This is to ensure that the management plan will be effective in preventing conflicts of interest from unduly influencing the conduct of the individual’s responsibilities. 

It is the responsibility of the individual to identify all potential elements of the conflict of interest. That individual may contribute to the development and implementation of the specific management plan. 

The management plan should be approved by the Department Chair or other appropriate senior administrator, and then by the Dean. A copy of the management plan, signed by the individual and the appropriate administrative parties noted herein. 

Procedures may be used alone or in combination to manage continued conflicts of interest. Conflicts of interest can be divided into low, medium, and high impact conflicts. Possible management strategies are outlined below. (this approach is based on a modification of the COI policy of the American College of Physicians) This applies to potential conflicts regardless of their direct or indirect nature. 

Should an individual with a COI concern disagree with Dean’s finding, in determining that an actual or potential conflict of interest exists, or disagree with the proposed remedy, the individual may submit an appeal to the Senior Associate Dean of Faculty Affairs. The Senior Associate Dean of Faculty Affairs will assemble an ad hoc committee of three (3) disinterested faculty peers. This committee will render a decision that will be communicated to the Dean for consideration. In the event of continued lack of agreement, a final appeal may be made to the Provost.

In rare instances, there may be justification to permit research to be undertaken without the elimination, reduction or management of significant financial conflicts of interest. 

The Dean may recommend in writing to the University COI Officer that an activity go forward without imposing conditions or restrictions, if the Dean determines that imposing such conditions or restrictions would be ineffective, and that the potential negative impacts that may arise from a significant financial interest, or other interest, are outweighed by interests of scientific progress, technology transfer, or the public health and welfare.

The Dean may also issue a written waiver that clinical or educational activity may go forward without imposing conditions or restrictions, if the Dean determines that imposing such conditions or restrictions would be ineffective, and that the potential negative impacts that may arise from a significant financial interest, or other interest, are outweighed by interests of scientific progress, technology transfer, or the public health and welfare.

Reporting Responsibilities Related to Research:

In accordance with University policy, investigators must complete an “Investigator Disclosure Statement” when applying for funded research or prior to activation of an award, whichever occurs first, before submission of a protocol to the IRB, within 30 days of discovering a new COI, and annually thereafter.  

Reporting Responsibilities Not Related to Research:

Full time Faculty, Part time Faculty, and Staff must update a conflict of interest statement and complete an educational component at least annually as part of their annual faculty report. They should also update sooner if a new conflict arises.  

Volunteer Faculty must update a conflict of interest statement and complete an educational component at least every three years as part of their volunteer faculty appointment or reappointment process. They should also update sooner if a new conflict arises. 

Noncompliance with this policy may result in disciplinary action. Any disciplinary action must be consistent with established School, University, and SUNY Board of Trustees policies, and applicable collective bargaining agreements.