Policy on Conflicts of Commitment and Interest

Conflict of Commitment

SPH faculty and staff owe their professional allegiance to Texas A&M HSC, and their primary commitment of time and intellectual energies should be to the education, research and scholarship programs of the institution.  The specific responsibilities and professional activities that constitute that commitment will differ across components and departments, but they should be based on a general understanding between the faculty member, staff member or trainee and his or her department chair and component dean/director.  Even with such understandings in place, however, attempts of faculty, staff and trainees to balance Texas A&M HSC responsibilities with external activities - such as consulting, public service or pro bono work - can result in conflicts regarding allocation of time and energies. Conflicts of commitment usually involve issues of time allocation.  Whenever an individual's outside consulting activities (as defined in Texas A&M University System Regulation 31.05.01 Faculty Consulting, External Employment and Conflicts of Interest) exceed the permitted limits, a potential conflict occurs.  A conflict of commitment exists when too large a proportion of an individual’s professional activities are focused on tasks or goals that do not assist the Texas A&M HSC in carrying out its mission.

 

Conflict of Interest

A conflict of interest occurs when there is a divergence between an individual's private interests and his or her obligations to Texas A&M HSC such that an independent observer might reasonably question whether the individual's professional actions or decisions (e.g., research results or commentary on scientific matters) are determined by considerations of personal gain, financial or otherwise rather than a commitment to seeking and transmitting scientifically sound information.

Conflicts of interest are common and practically unavoidable in a modern research university.  Therefore, it is paramount that policies and procedures be put in place to manage potential conflicts of interest.  At Texas A&M HSC, conflicts of interest can arise out of the fact that a mission of the Texas A&M HSC is to promote public good by fostering the transfer of knowledge gained through Texas A&M HSC research and scholarship to the private sector.  Two important means of accomplishing this mission include consulting and the commercialization of technologies derived from research.  It is appropriate that individuals be rewarded for their participation in these activities through consulting fees and sharing in royalties resulting from the commercialization of their work.  It is wrong, however, for an individual's actions or decisions made in the course of his or her Texas A&M HSC activities to be determined by considerations of personal financial gain.  Such behavior calls into question the professional objectivity and ethics of the individual and it also reflects negatively on Texas A&M HSC.  Texas A&M HSC is an institution of public trust; all members must respect that status and conduct their affairs in ways that will not compromise the integrity of Texas A&M HSC.

Faculty, staff and trainees should conduct their affairs so as to appropriately manage conflicts of interest when they arise.  To that end, the purposes of this internal policy and guidelines are to educate individuals about situations that generate conflicts of interest, to provide means to manage conflicts of interest, to promote the best interests of trainees and others whose work depends on faculty direction, and to describe situations that are prohibited.  Every individual has an obligation to become familiar with, and abide by, the provisions of this internal policy.  If a situation of potential conflict of commitment or interest arises, individuals are urged to discuss the situation with the department chair, component dean/director, or the Vice President for Academic Affairs (or Vice President for Research, where appropriate).

 

Procedures

Faculty, staff and trainees are urged to read the associated Texas A&M HSC guidelines outlined in Texas A&M HSC Guideline 12.01.99.Z1.04 to fully understand the spirit of these provisions, the bona fide exceptions, and requirements for compliance.

The SPH Office of the Dean will notify faculty and staff of the need to comply with this policy and guidelines on an annual basis.

All SPH faculty and staff must certify in writing to the component deans/directors their compliance with the Texas A&M HSC internal policy related to conflict of interest and commitment.  Faculty members will do so at the time of initial faculty appointment; staff members will do so at the point of hire; and trainees will do so at matriculation.

Faculty and staff must also disclose information about their (and their immediate family members) financial relationships with outside organizations that are sponsors of their teaching or research programs or are otherwise involved in current, proposed or pending financial relationships with Texas A&M HSC that involve the individual.

Department Heads will review disclosure forms of faculty for potential or apparent conflicts to ensure (in consultation with the SPH Office of Academic Affairs, the SPH Office of Research, the Texas A&M HSC Office of the Vice President for Academic Affairs for education or training related conflicts, and the Texas A&M HSC Office of the Vice President for Research and Graduate Studies for research related conflicts) the appropriate management of such conflicts.

The SPH Office of Business Affairs will review disclosure forms of staff  for potential or apparent conflicts to the appropriate management of such conflicts.

The Vice President for Academic Affairs (or Vice President for Research, where appropriate) shall hear appeals to decisions regarding conflict of commitment and interest.

Should an individual wish to appeal a decision made by the Vice President for Academic Affairs or Vice President for Research, he or she may present the appeal to the Texas A&M HSC Executive Vice President & CEO only on the basis that the decision was made in violation of the academic freedom of the individual or for an illegal reason or for inadequate consideration of the faculty member’s record of professional accomplishment.