Research Affairs / 
Research Conflict of Interest


Note:  The following information reflects the revised Research Conflict of Interest policy (Faculty Handbook, section 3.4.13) approved by the Board of Trustees on May 23, 2012.

What is conflict of interest in research?
To whom does this apply?
What should be reported?
When should Significant Financial Interests (SFI) be disclosed?
Where do you go for training?
Where do you send SFI Disclosure forms for review?
Resources & Contact Information


What is conflict of interest in research?

The federal definition of a research conflict of interest includes situations in which Significant Financial Interests may compromise, or have the appearance of compromising, an investigator’s professional judgment in the design, conduct or reporting of research.

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To whom does this apply?

The Research Conflict of Interest policy and procedure (H-35) requires that all personnel involved in the design, conduct, or reporting of a research project, contract, sub-contract, agreement or protocol must complete the training and disclose Significant Financial Interests (SFIs) that reasonably appear to be related to their institutional responsibilities (i.e., research, teaching, professional practice, institutional committee memberships, and services on panels such as the Institutional Review Board). This includes but is not limited to:

  • Principal Investigators;
  • Co-Investigators;
  • Research Coordinators;
  • Research Assistants;
  • Technical Staff;
  • Administrative Staff;
  • Residents and students; and
  • Collaborators involved in the design, conduct, or reporting of a research project.

Disclosures must include the Significant Financial Interests of family members. This includes all persons related by blood or marriage, financial dependents, and persons in intimate relationships.

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What should be reported?

  • Publicly Traded Companies: Research Conflict of Interest
    • Combined equity value (ownership of stock, options, etc. ) AND income exceeding $5,000 (or the equivalent cash value) from any one entity during the preceding 12 months, that when aggregated for the investigator and family appears to be related to your institutional responsibilities.
  • Privately Held or Nonprofit Companies:
    • Any ownership in any dollar amount or income exceeding $5,000 (or the equivalent cash value) from any one entity that when aggregated for the investigator and family appears to be related to your institutional responsibilities.
  • Intellectual Property Rights (e.g., patents, copyrights) from which you received any income, and the intellectual property appears to be related to your institutional responsibilities.

  • Sponsored Travel paid for, or reimbursed directly to you, by an organization other than an accredited U.S. institution of higher education (including LLUAHSC) or by any U.S. government agency (federal, state, or local) when the sponsoring organization appears to be related to your institutional responsibilities; and the aggregate dollar value of the travel from this sponsor exceeds $5,000 in the preceding 12 months.

  • Paid Positions of Influence in which you exercised an authoritative or direction-shaping role in any entity not affiliated with LLUAHSC (including non-profit organizations) and the interests of the entity appear to be related to your institutional responsibilities.

  • Example of a potential conflict: A pharmaceutical company directly pays for your ticket to travel to a conference where you earn CME credit towards your medical license renewal.

    Example of a non-conflict: Income from, or investments in, mutual funds or retirement funds, where you have no control of investment choices.

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    When should Significant Financial Interests be reported?

    Significant Financial Interests must be disclosed:

  • At the time a project is proposed (new grant submissions, new contract executions, new protocol submissions.)
  • Annually (on or before the anniversary date of project start period)
  • At the time an amendment is submitted, if the amendment involves the addition of new personnel to the research project.
  • Within 30 days of a change in a financial interest.

    PLEASE NOTE: Grants will not be submitted and projects will not receive final approval until disclosure forms from ALL personnel listed on the project are submitted and have received clearance, or identified conflicts have been managed.

    Incomplete forms may delay processing. It is the Principal Investigator's responsibility to identify all personnel involved in the project on the disclosure form. Each person listed, however, must submit his/her own form. To expedite your research please submit the disclosure forms in a timely manner.

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    Where do you go for training?

    All investigators must complete the online course before submitting a SFI Disclosure form. This training must be repeated every 4 years. Registering for the online training course and submitting a disclosure vary by the investigator's relationship to Loma Linda University Health. Instructions can be found here.

    If it is determined that there is a significant conflict of interest, the forms will be further reviewed by the Research Conflict of Interest Committee.

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    Where do you send SFI Disclosure forms for review?

    SFI Disclosure forms should be submitted via the electronic Significant Financial Interest Disclosure system.

    If it is determined that there is a significant conflict of interest, the forms will be further reviewed by the Research Conflict of Interest Committee.

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    Resources & Contact Information:

    Research Conflict of Interest and Disclosure Resources:


    Research Disclosure Resources for non-LLU personnel: