Conflict of Interest

Brown University's Conflict of Interest and Commitment Policy and Conflict of Interest in Research Policy

The University’s Conflict of Interest and Commitment Policy, which applies to all members of the Brown community, outlines the University’s rules and practices for avoiding or managing conflicts of interest (COI) and conflicts of commitment (CoC) of its faculty, staff, researchers, and students.  All members of the Brown community should familiarize themselves with this policy, which lays out COI reporting requirements and includes a section on acceptable personal gifts. 

The Conflict of Interest in Research policy applies to all researchers at Brown. The policy, which incorporates PHS COI regulations 42 CFR 50 Subpart F and Department of Energy (DoE) FAR2022-02, details Brown's rules and practices related to the review and management of research conflicts. It also outlines reporting requirements and includes specific sections on presumptively prohibited conflicts at Brown, rules and practices at the University related to SBIR/STTR grant submissions, and prohibitions around self-funding of research involving personnel.

Important Links and Resources

• Brown University Conflict of Interest and Commitment:
  Brown University's overarching conflict of interest policy, which applies to all members of the Brown community.

• Brown University COI in Research Policy: 
  Brown University’s policy on identifying and managing conflicts of interest in research, which applies to all Investigators on research administered through or otherwise conducted under the auspices of the University. 

• Electronic Conflict of Interest Reporting for Faculty and Researchers:
  Faculty and researchers complete and/or update their COI Reporting form in InfoEd. See here for more details on electronic COI reporting for faculty and researchers. Please also review the special Requirements for Investigators funded by PHS, DoE, or foundations that follow PHS COI regulations for additional reporting requirements.

• Electronic Conflict of Interest Reporting for University Staff:
  University staff complete their COI reporting in Workday. See here for more information about staff COI reporting, which is facilitated by the Office of Human Resources.

• COI Training:
  Click here if you need to complete COI training.

• COI Frequently Asked Questions (FAQs)

• Contact information for the COI administrative staff.

Federal Regulations and Policies

• Federal COI Regulations/Federal Register Final Rule (August 25, 2011): 42 C.F.R. 50 Subpart F

• NSF AAG Chapter IV.A contains NSF’s policy on conflict of interest: Grantee Standard IV

• Physician Payment Sunshine Act & Open Payments Website

  • Open Payments on CMS.gov: https://www.cms.gov/openpayments/

  • “Physician Payment Sunshine Act 2009 Introduced”, Policy & Medicine, Jan 22, 2009

• Federal COI Regulations (Department of Energy): FAL2022-02

• NASA's Conflict of Interest Policy (08/31/2023): GCAM section 3.3, Conflicts of Interest Policy