As a public institute entrusted with public funds to carry out its research and educational missions, SUNY Downstate Health Sciences University (DHSU) must ensure that its activities are conducted in an ethical, transparent, and bias-free environment to maintain the public trust. In conjunction with DHSU's Code of Conduct and the SUNY/RF Standards of Review (below), the Conflict of Interest Policy was created to guide DHSU Investigators in their everyday work, to outline required and prohibited conduct, and to provide guidance on how potential perceived or actual conflicts of interest can be managed so as to enable industry and commercial partnerships, which are essential to advance our missions.
The development of collaborative partnerships between academic research with external individuals and entities to enhance discoveries and their application to improve human health is a stated goal of SUNY, the Research Foundation of SUNY, and the National Institutes of Health. External entities may include other educational and research institutions or private businesses such as established companies or start-ups. While encouraged, outside activities may also create real, potential, or apparent conflicts of interest, any of which may harm or damage the reputation of the individual investigator or DHSU and violate Public Officer's law. This Policy provides guidance for complying with the Federal revised regulation - Responsibility of Applicants for Promoting Objectivity in Research for which Public Health Service Funding is Sought and Responsible Contractors -while furthering the missions of DHSU and the investigator. However, under this policy, the development of a license with the Office of Technology Transfer will require a review of potential conflicts that may emerge between academic and planned commercial research operations once the commercialized entity comes into existence.
DHSU Investigators hold positions of trust and must act in the best interests of the public and DHSU. A COI arises if personal financial relationships or activities interfere, or appear (could be perceived) to interfere, with the individual's ability to act in the public's and DHSU's best interests. DHSU Investigators are therefore obliged to redesign any activity that impairs or would reasonably appear to impair the individual's ability to perform his/her duties with independence and objectivity. Such redesign might include mechanisms for disclosure, transparency, and third party participation and oversight that would enable rather than curtail an activity.
The Financial Conflict of Interest Committee (FCOIC) of SUNY Downstate was created to review financial disclosures and research operations for significant perceived or actual conflict, and based on that, to develop Management Plans to mitigate any perceived or actual conflict so that collaborative partnerships such as those between academia and industry can flourish in ways that comply with Federal and State COI mandates. The FCOIC's mission is to review investigator's annual and transactional disclosures to determine whether perceived or actual conflict exists between the investigator's research and their financial interests. Where such an actual or perceived conflict is determined to exist, the FCOIC, in conjunction with the investigator, will create a mutually agreed-upon Management Plan which will strive to remove or mitigate the conflict by creating mechanisms for disclosure, transparency, and third party participation and oversight that would enable, rather than curtail or eliminate the activity itself. These Management Plans must be reviewed and monitored throughout the life of the research project and investigator's research period at DHSU.
SUNY Policies and Procedures: https://www.suny.edu/sunypp/