/Office for Research and Innovation
Research Security

Research Conflict of Interest & Conflict of Commitment Program

The Research Conflict of Interest and Conflict of Commitment (COI/COC) Program supports the integrity, objectivity, and transparency of University research by providing a framework for identifying, reviewing, and managing external interests and commitments that may affect—or appear to affect—an individual's research or University responsibilities.

The Office of Research Security (ORS) administers the Research COI/COC Program in accordance with the University's Disclosure of External Interests & Commitments Policy, applicable University procedures, and federal sponsor requirements.

Stony Brook University encourages appropriate outside professional activities, collaborations, consulting, entrepreneurship, and other external relationships that advance research, scholarship, innovation, education, and public service. Disclosure of an external interest or commitment does not necessarily mean that a conflict exists. Disclosure and institutional review allow potential conflicts to be identified and, when necessary, appropriately managed while supporting productive external engagement.

VIEW UNIVERSITY DISCLOSURE REQUIREMENTS
COMPLETE YOUR DISCLOSURE PROFILE
CONTACT ORS

Understanding Conflict of Interest & Conflict of Commitment

Conflict of Interest and Conflict of Commitment are related but distinct concepts. An external activity or relationship may involve one, both, or neither.

Conflict of Interest (COI)

A Conflict of Interest may arise when an individual's financial or personal interests could affect—or appear to affect—their professional judgment, research decisions, or University responsibilities.

Examples may include financial interests associated with:

  • consulting;
  • startup companies;
  • equity or ownership interests;
  • royalties or intellectual property;
  • advisory or leadership roles; or
  • other relationships with entities whose interests relate to an individual's research or University responsibilities.

Learn more about Conflict of Interest

Conflict of Commitment (COC)

A Conflict of Commitment may arise when outside professional activities, appointments, affiliations, or other external commitments interfere—or reasonably appear to interfere—with an individual's ability to fulfill their responsibilities to Stony Brook University.

Examples may include:

  • outside academic or research appointments;
  • ongoing consulting commitments;
  • external employment or leadership responsibilities;
  • domestic or international research affiliations;
  • outside research activities or support; or
  • other professional commitments that create competing responsibilities.

Learn more about Conflict of Commitment

Who Is Subject to Research COI/COC Requirements?

Research COI/COC requirements apply to individuals subject to the University's Disclosure of External Interests & Commitments Policy and may also arise from federal sponsor requirements, award terms, or other applicable University requirements.

Requirements may vary based on an individual's University role, research responsibilities, funding source, sponsor, and external interests or commitments.

Researchers should review applicable University and sponsor requirements and contact ORS if they are unsure whether a disclosure, training, or other Research COI/COC requirement applies.

Researcher Responsibilities

Individuals subject to Research COI/COC requirements are responsible for:

  • completing required University disclosures of external interests and commitments;
  • maintaining a complete and current Disclosure Profile;
  • completing required Conflict of Interest training;
  • providing additional information requested as part of University review;
  • complying with applicable federal sponsor disclosure and Conflict of Interest requirements;
  • disclosing relevant changes when required; and
  • complying with any Conflict Management Plan or other measures established by the University.

University disclosure requirements and federal sponsor disclosure requirements are related but separate obligations. Disclosure to the University does not necessarily satisfy a sponsor disclosure requirement, and disclosure to a sponsor does not necessarily satisfy University requirements.

Disclosure Requirements

The University's Disclosure of External Interests & Commitments Policy establishes requirements for disclosure of certain external financial interests, professional activities, appointments, affiliations, and other commitments.

Disclosures are submitted and maintained through the University's Disclosure Profile.

Researchers should keep their Disclosure Profile current and update it when required by University policy.

Disclosure does not mean that a Conflict of Interest or Conflict of Commitment exists. ORS reviews disclosed information in relation to an individual's research and University responsibilities to determine whether additional review or management is necessary.

Learn more about University Disclosure Requirements 

Federal research sponsors may impose separate disclosure requirements involving financial interests, outside appointments and affiliations, research support, in-kind resources, Current and Pending (Other) Support, and other professional activities.

Learn more about Federal Sponsor Disclosure Requirements

Conflict of Interest Training

Individuals subject to the University's research COI training requirements must complete Conflict of Interest (COI) Training through the Collaborative Institutional Training Initiative (CITI).

COI training must be completed:

  • before engaging in funded research activities;
  • at least every four years; and
  • immediately when required because:
    • University policies change in a manner that affects applicable training requirements;
    • an individual subject to the requirement is new to the University; or
    • the University determines that an individual has not complied with applicable COI requirements or a Conflict Management Plan.

How to Complete COI Training

  1. Log in to CITI using Log In Through My Organization with your Stony Brook NetID.
  2. Select Add a Course.
  3. Select the applicable Conflict of Interest course.
  4. Complete all required modules.

Completion through CITI creates the University's official training record.

COI Training is separate from Research Security Training. Completion of one does not satisfy the requirement for the other.

COMPLETE COI TRAINING

How ORS Reviews Disclosed Interests & Commitments

ORS reviews disclosed interests and commitments in relation to an individual's research and University responsibilities and applicable University and sponsor requirements.

Depending on the circumstances, the review may consider:

  • the nature and value of an external financial interest;
  • the individual's role or relationship with an external entity;
  • the relationship between the external entity and the individual's University research;
  • outside appointments, employment, consulting, or other professional commitments;
  • time and effort associated with external activities;
  • externally provided research support, resources, personnel, or facilities;
  • potential effects on research objectivity or University responsibilities;
  • applicable federal sponsor requirements;
  • research security, export control, or other compliance considerations, when relevant; and
  • whether identified concerns can be appropriately managed.

ORS may request additional information from the researcher or coordinate with other University offices when necessary to complete the review.

Review & Determination

Following review, ORS may determine that:

  • No Conflict Exists — the disclosed interest or commitment does not create a Conflict of Interest or Conflict of Commitment requiring management;
  • Additional Information or Review Is Needed — additional information or consultation with the researcher or other University offices is necessary;
  • A Conflict of Interest Exists — the external interest requires appropriate management;
  • A Conflict of Commitment Exists — the external commitment requires appropriate coordination or management; or
  • Both COI and COC Considerations Exist — the activity presents both financial or personal interest considerations and competing commitment considerations.

The existence of a conflict does not necessarily mean that the external activity or research must end. Many conflicts can be appropriately addressed through disclosure, transparency, oversight, coordination, and other management measures.

Conflict Management

When a Conflict of Interest or Conflict of Commitment is identified, ORS works with the researcher, appropriate academic or administrative leadership, the Conflict of Interest Committee when applicable, and other University offices to determine appropriate management measures.

Depending on the circumstances, measures may include:

  • disclosure to research team members, collaborators, sponsors, publications, or research participants;
  • independent review or oversight of research activities;
  • modification of research roles or responsibilities;
  • clarification or modification of outside professional commitments;
  • recusal from specific institutional decisions;
  • coordination with academic or administrative leadership;
  • sponsor notification or disclosure, when required;
  • monitoring of approved arrangements;
  • restrictions involving students, trainees, or other supervised personnel; or
  • other measures appropriate to the circumstances.

Conflict management is intended to protect research integrity, objectivity, research participants, students and trainees, and public trust while allowing appropriate research and external professional activities to proceed whenever possible.

Learn more about Conflict Management Plans 

Publication Disclosure Statements for Conflict of Interest

Federal Sponsor Requirements

Federal research sponsors may establish additional requirements related to financial conflicts of interest, outside professional activities, appointments and affiliations, research support, and other external interests or commitments.

Sponsor requirements may include:

  • financial Conflict of Interest disclosure and reporting;
  • disclosure of outside appointments and affiliations;
  • disclosure of consulting or other professional activities;
  • Current and Pending (Other) Support;
  • disclosure of in-kind research resources;
  • certification of compliance with institutional COI requirements;
  • sponsor notification or reporting of identified conflicts;
  • additional training requirements; and
  • restrictions involving certain foreign affiliations or activities.

Sponsor requirements vary and may change over time. Researchers are responsible for ensuring that information provided to sponsors is complete, accurate, and consistent with applicable University disclosures.

Learn more about Federal Sponsor Disclosure Requirements →

Related Research Security Requirements

External interests and commitments may also intersect with other research security requirements.

Depending on the activity, ORS may consider whether additional review is needed involving:

  • international research collaborations;
  • foreign appointments or affiliations;
  • foreign talent recruitment programs;
  • export controls;
  • restricted entities or countries;
  • international research agreements;
  • sponsor research security requirements; or
  • research information protection and cybersecurity.

Review under the Research COI/COC Program does not replace any separate review or authorization required under another University or sponsor process.

When Should I Contact ORS?

Researchers are encouraged to contact ORS early when considering an external activity or relationship that may intersect with their research or University responsibilities, including:

  • establishing or joining a startup company related to University research;
  • accepting equity or another ownership interest in an entity related to their research;
  • consulting for an entity that sponsors, supports, or may benefit from their research;
  • accepting an outside academic, research, visiting, honorary, or other professional appointment;
  • serving as an officer, director, trustee, executive, or scientific advisory board member;
  • participating in an international research affiliation or appointment;
  • receiving outside research support, personnel, equipment, laboratory space, or other resources;
  • licensing or commercializing University-developed technology;
  • conducting research involving an entity with which they have a financial relationship;
  • participating in a foreign talent recruitment program; or
  • engaging in another outside activity that may affect research objectivity, sponsored research commitments, sponsor disclosure requirements, or University responsibilities.

Early consultation can help identify applicable requirements and address potential concerns before they affect proposal submission, award acceptance, research activities, international collaborations, or technology commercialization.

How ORS Can Assist

ORS works collaboratively with researchers, academic units, and University partners to:

  • explain University disclosure and Research COI/COC requirements;
  • provide guidance regarding COI training requirements;
  • review disclosed external interests and commitments;
  • identify potential Conflict of Interest and Conflict of Commitment considerations;
  • coordinate review with the Conflict of Interest Committee and other University offices, as appropriate;
  • assist with applicable federal sponsor COI and disclosure requirements;
  • identify related research security or export control considerations;
  • develop Conflict Management Plans or other management measures, when appropriate; and
  • support compliance with University policy and applicable federal requirements.

Most external interests and commitments can be appropriately addressed through disclosure, transparency, coordination, and, when necessary, appropriate management measures.

Related Guidance & Resources

Research COI/COC Guidance

Disclosure Guidance

University Policies and Procedures

Questions?

Contact the Office of Research Security (ORS) if you have questions about:

  • University disclosure requirements;
  • Conflict of Interest or Conflict of Commitment;
  • COI training;
  • Conflict Management Plans;
  • federal sponsor COI or disclosure requirements; or
  • how an external interest, activity, appointment, affiliation, or commitment may affect your research or University responsibilities.

Disclosure of an external interest or commitment does not necessarily mean that a conflict exists. Early consultation allows ORS to identify applicable requirements and help researchers appropriately manage potential concerns while supporting research, collaboration, innovation, and external professional engagement.