Conflict of Interest: A set of circumstances in which the Professional Interests or duties of an individual, such as professional obligations or judgment owed to Tulane and its constituencies by a Faculty member, Staff member, or affiliated Investigator, are compromised by, or could reasonably be perceived as being compromised by, his or her Leadership Role(s), Financial Interest(s), Research Leadership Role(s), or Research Financial Interest(s).

Designated Officials: The designated officials of the University for purposes of reviewing, administering, and implementing Conflicts of Commitment and Conflicts of Interest determinations shall be the President, the Senior Vice President for Academic Affairs and Provost, the Senior Vice President and Dean of the School of Medicine, the Deans and the Vice Deans of the Schools of Medicine, Public Health and Tropical Medicine, Architecture, Business, Science and Engineering, Newcomb-Tulane College, Law, Liberal Arts, Social Work, and Professional Advancement; the Director of the Tulane National Primate Research Center, the Vice President for Research, the Senior Vice President and Chief Operating Officer, the Senior Vice President for Advancement, the Vice President, Secretary of the University and Chief of Staff, the CEO of TUMG, the Internal Auditor and the Office of the General Counsel. Chairs of the IACUC, IRB and other University administrators or staff may be called upon, as needed, by the Senior Vice Presidents or by the COI Committee for specific purposes.

Faculty: Persons holding academic appointments of employment with Tulane.

Financial Interest: Anything of monetary value, whether or not the value is readily ascertainable, consisting of one or more of the following interests of a Faculty or Staff member or an Investigator (and those of the Faculty or Staff member’s or the Investigator’s spouse and dependent children) that reasonably appears to be related to the Faculty or Staff member’s or Investigator’s institutional responsibilities, including any of the following received by an individual in any capacity or for any reason (note that for this purpose the term “individual” includes the individual and any member of the individual’s Immediate Family), and “payments” includes cash, monetary instruments such as checks and bearer instruments, compensation, valuable goods and services, travel reimbursements, travel vouchers, and pre-paid travel expenses):

  1. Any payment(s) received from or equity interest(s) held in a publicly traded entity during the 12-month period prior to the disclosure with a value that, in the aggregate, exceeds $5,000;
  2. Any payment(s) received from a non-publicly traded entity during the 12-month period prior to the disclosure with a value that, in the aggregate, exceeds $5,000;
  3. Any equity interest in a non-publicly traded entity;
  4. Income of more than $5,000 (from any one entity) generated from intellectual property rights and interests, unless paid by the University to an individual employed or appointed by the University;
  5. Reimbursed or sponsored travel with a value that exceeds $5,000, unless reimbursed or sponsored by the University or a U.S. federal, state or local government agency, a U.S. institution of higher education as defined in 20 U.S.C. § 1001(a), a U.S. academic teaching hospital, a U.S. medical center, or a U.S. research institute affiliated with an institution of higher education.
  6. Any payments, compensation, valuable goods or services received from a foreign government office, unit or agency (local, provincial or national), a foreign institution of higher education, a foreign academic teaching hospital, a foreign medical center, or a foreign research institute must be disclosed.  For avoidance of doubt, this includes, for example,  compensation and honoraria from teaching engagements, seminars, lectures, and presentations, travel expenses and reimbursements, and gift items that exceed $5,000 in value or that are of indeterminate value (such as works of art).

A Financial Interest must be disclosed by Faculty, Staff and Investigators if it is related to that individual’s professional responsibilities on behalf of the University.  These responsibilities may include, for example, activities such as research and research consultation, teaching, professional practice, institutional committee memberships, and service on IRBs or safety monitoring boards.

Notwithstanding the foregoing, a Financial Interest does not include the following:

  1. Salary, royalties, or other remuneration paid by the University to an individual if the individual is currently employed or otherwise appointed by the University, including intellectual property rights assigned to the University and agreements to share in royalties related to such rights.
  2. Salary, royalties, or other remuneration paid by a Subrecipient to an individual if the individual is currently employed or otherwise appointed by the Subrecipient, including intellectual property rights assigned to the Subrecipient and agreements to share in royalties related to such rights. This exception may not apply to Faculty, Staff or Investigator companies, which will be evaluated on a case-by-case basis.
  3. Any ownership interest in a Subrecipient held by the Investigator, if (a) the entity is a commercial or for-profit organization, and (b) the Investigator is participating in the research as an Investigator only at the Subrecipient level.
  4. Income from investments in which the day-to-day control of investments is held by a person not subject to this policy or any other University conflict of interest policy.
  5. Income from teaching engagements, seminars or lectures paid by a U.S. federal, state or local government agency, a U.S. institution of higher education as defined in 20 U.S.C. § 1001(a), a U.S. academic teaching hospital, a U.S. medical center or a U.S. research institute affiliated with an institution of higher education.
  6. Income from service on advisory committees or review panels for a U.S. federal, state or local government agency, a U.S. institution of higher education as defined in 20 U.S.C. § 1001(a), a U.S. academic teaching hospital, a U.S. medical center, or a U.S. research institute affiliated with an institution of higher education.

Immediate Family: Spouse or domestic partner, children (including adoptees) and other dependents.

Because of strict conflict of interest rules required by federal and state law, the definition of Immediate Family for a member of the Tulane University Medical Group and for other health care providers is: Spouse or domestic partner, children and other dependents, natural or adoptive parents, siblings, stepparent, stepchild, stepbrother or sister, father-in-law, mother-in-law, daughter-in-law, son-in-law, brother-in-law, sister-in-law, grandparent, grandchild, and spouse of grandparent or grandchild.

A healthcare provider is a physician or other health care professional or Staff member who orders medical items, supplies (including for example pharmaceuticals) or services for patients or who refers patients to other health care providers or suppliers of medical items, supplies or services. A physician or other Staff member who performs no patient care services, directly or indirectly, and whose duties encompass no direct or indirect patient care is NOT covered by this definition of healthcare.

For purposes of evaluating Vendor relationships, Immediate Family also includes parents, siblings, parents-in-law, and siblings-in-law.

Institutional Review Board (IRB): Any board, committee or other group formally designated by the University to review human subjects research, and which was established and which functions and operates in conformity with Part 46 of Title 45 and Part 56 of Title 21 of the Code of Federal Regulations. IRB Members are those persons who constitute the IRB.

Investigator: Any Faculty, Staff or affiliated person who serves as a project director or principal investigator or who, regardless of title or position, is responsible for the design, conduct or reporting of research. Investigator may include, for example, a collaborator, consultant, or contractor.

Leadership Role:

  1. Employment in any executive or administrator capacity
  2. Consulting in any executive or administrator capacity
  3. Serving as
    1. a member of a board of trustees, directors, or administrators
    2. an officer
    3. a member of an advisory committee, advisory board, or subcommittee of a board of trustees, directors or administrators

Any such employment, consulting or service by your Immediate Family member constitutes a Leadership Role on your part

A Leadership Role may be compensated or non-compensated.

Primary Commitment: The time, energy, fiduciary obligations, and loyalty that any Faculty or Staff member is required to dedicate to Tulane.

Professional Interests: Academic, research, personal, professional and/or institutional integrity, patient safety and welfare, or any other interest that may be added to this policy from time to time.

Research Financial Interest:

  1. Any investments (whether in the form of debt, stock or other equity ownership, options or warrants to purchase stock or other securities or similar instruments) or interest in a Sponsor, research or health care-related organization;
  2. Royalties on any patent or other intellectual property interests, unless paid by Tulane
  3. Income, salary or remuneration in cash or in kind, emoluments, benefits, gifts, honoraria, travel expenses, goods or services received from a Sponsor or research or health care-related organization.

A Research Financial Interest has no dollar or ownership thresholds; therefore, any interest related to a Sponsor or to the research must be disclosed, however small.

Research Leadership Role: Leadership Role in a research Sponsor or research-related organization.

Research Oversight Official: Faculty and Staff of any institutional office or body (for instance, all Institutional Review Board (IRB), Institutional Animal Care and Use Committee (IACUC), and Institutional Biosafety Committee (IBC) members) at Tulane who perform research oversight functions in which they exercise professional or administrative-level discretion. All Designated Officials in the Tulane University Policies on Conflicts of Commitment and Interest are also Research Oversight Officials.

An Investigator is not a Research Oversight Official simply because he or she is an investigator.

Secondary Commitment: An activity that is not part of your Primary Commitment to Tulane (where Primary Commitment means the time, energy, fiduciary obligations, and loyalty you are required to dedicate to Tulane) and which imposes demands from outside entities, organizations, or projects for your time, energy, fiduciary obligations, or loyalty. Secondary Commitments may include but are not limited to employment, consulting, or other participation in outside businesses or organizations, as well as non-Tulane Leadership Roles and other such compensated or non-compensated activities.

Any such employment, consulting or service by your Immediate Family member may constitute a Secondary Commitment on your part.

Secondary Commitments do not include activities conducted entirely on personal time, which have no conflicting effect on one’s Primary Commitment and which do not reasonably create the appearance of such a conflict.

Sponsor: The entity that is sponsoring or funding the research and the entity’s affiliates and subsidiaries, and any entity that monitors research, collects or arranges data for research or otherwise performs any services related to or supporting research, including without limitation assisting in applications or responses to the United States Department of Health and Human Services and/or the United States Food and Drug Administration.

Staff: Persons holding non-academic employment with Tulane. For purposes of this policy, Staff shall include administrators who do not have academic appointments with Tulane.

Vendor/Contractor: Any individual, business, partnership, corporation or other entity that sells or conveys goods or services to the University, or that arranges for the purchase or sale of goods or services to, for or by the University.