University of California, Santa Barbara
IN-3: Academy-Industry Connections

1. Require that all significant consulting contracts (e.g. those worth $5,000 or more a year) be reported to a standing committee charged with reviewing and managing individual and institutional conflicts of interest;

UCSB’s Conflict of Interest Committee (COIC) manages conflicts of interest in research and reviews disclosure forms related to funded research. The latter depends upon the entity that an investigator has submitted a research proposal to and/or is receiving funding from. The phrase “significant consulting contracts” can have different definitions based on the source of funding. The policies and disclosure forms required to assess a conflict of interest for various entities are outlined below.
- Public Health Service (PHS):
The policy states: “A Significant Financial Interest that is related to the PHS-funded research activity in which the Investigator is engaged and that could directly and significantly affect the design, conduct and/or reporting of PHS-funded research activity.”
The monetary threshold is $5,000 in a 12 month period, which requires review by the COIC. Specific details about the policy can be found here: https://policy.ucop.edu/doc/2500558/PHS_COI
- National Science Foundation (NSF):
The policy states: “The term "significant financial interest" means anything of monetary value, including, but not limited to, salary or other payments for services (e.g., consulting fees or honoraria); equity interest (e.g., stocks, stock options or other ownership interests); and intellectual property rights (e.g., patents, copyrights and royalties from such rights).”
The monetary threshold is $10,000 in a 12 month period, which requires a review by the COIC. Specific details about the policy can be found here: https://www.nsf.gov/pubs/policydocs/pappguide/nsf16001/aag_4.jsp#IVA
- Other governmental entities:
Some governmental entities issuing contracts and grants to the University require conflict of interest disclosure and review, but they do not have specific language to define what a Significant Financial Interest entails. The COIC uses disclosure forms from the aforementioned entities to collect this information and reviews the potential conflicts of interest accordingly.
- Private Sponsors of Research:
APM - 028, Disclosure of Financial Interest in Private Sponsors of Research, is currently undergoing Systemwide Review. The proposed revisions involve splitting the current APM - 028 into two separate documents: APM - 028 and a 700-U form. Comments on the proposed revisions are due by June 27, 2018. Here is the current APM - 028 policy: https://www.ucop.edu/academic-personnel-programs/_files/apm/apm-028.pdf. The proposed APM - 028 would serve as guidelines to establish the UC’s policy on disclosure of financial interests for private funding. Here is the proposed draft: https://www.ucop.edu/academic-personnel-programs/_files/apm/apm-028-and-pres-policy/DRAFT%20028-04-10%20clean%203-29-18.pdf. The proposed Conflict of Interest 700-U Policy explains the review process for disclosures of financial interests that require an investigator to fill out a 700-U form. The term “financial interest” is defined differently depending on what form the funding comes in - as an investment, income, a loan, and/or a gift. The draft policy can be accessed here: https://www.ucop.edu/academic-personnel-programs/_files/apm/apm-028-and-pres-policy/coi-700-u-policy-sys-rvw.pdf. Investigators fill out the 700-U form if applicable, and the COIC reviews the forms. Here is Form 700-U: https://www.research.ucsb.edu/media/11168/form_700_u_2016_2017.pdf.
- Institute for Collaborative Biotechnologies (ICB):
UCSB’s University Affiliated Research Center (UARC) is the Institute for Collaborative Biotechnologies (ICB). There is a clause within the ICB’s contract with the Army that requires investigators working on Army funded research to disclose conflicts of interest.

2. Prohibit faculty, students, postdoctoral fellows, medical residents, and other academic professionals from engaging in industry-led “ghostwriting” or “ghost authorship”;

Ghost authorship is implicitly mentioned in two sections of the Academic Personnel Manual (APM). APM - 190 pertains to faculty and students involved in research, and APM - 015 pertains to faculty.
- APM - 190 Appendix B: University Policy on Integrity in Research
The policy contains the following language: “University policies set forth expectations for high standards of ethical behavior for faculty and students involved in research and provide procedures for addressing allegations of misconduct in research… Misconduct means fabrication, falsification, plagiarism, or other practices that seriously deviate from those that are commonly accepted within the scholarly and scientific community for proposing, conducting, or reporting research.” It can be accessed here: https://www.ucop.edu/academic-personnel-programs/_files/apm/apm-190-b.pdf.
- APM - 015: The Faculty Code of Conduct
The policy contains the following language under the Scholarship heading in Part II: “Types of unacceptable conduct: Violation of canons of intellectual honesty, such as research misconduct and/or intentional misappropriation of the writings, research, and findings of others.” It can be accessed here: https://www.ucop.edu/academic-personnel-programs/_files/apm/apm-015.pdf.

3. Prohibit participation in sponsored research that restricts investigator access to the complete study data or that limits investigators’ ability to verify the accuracy and validity of final reported results;

This standard is addressed by the Principles Regarding Future Research Results written by the UC Office of the President. It can be accessed here: https://policy.ucop.edu/doc/2500487/PrinciplesRegardingResearchResults.

4. Ban confidential corporate research (i.e. research that cannot be published);

The Principles Regarding Future Research Results also address this topic. Two of the principles within this policy pertain to University relationships with external parties in regard to research publication. It can be accessed here: https://policy.ucop.edu/doc/2500487/PrinciplesRegardingResearchResults.
- Open Dissemination of Research Results and Information:
“Agreements with external parties shall not abridge the ability of University researchers to disseminate their research methods and results in a timely manner. The most fundamental tenet of the University is the freedom to interpret and publish or otherwise disseminate research results in order to support the transfer of knowledge to others and maintain an open academic environment that fosters intellectual creativity.”
- Public Benefit:
“Agreements with external parties shall support the ability of the University to make available for the public benefit in a diligent and timely manner any resulting innovations and works of authorship.”
The draft APM - 028 also mentions this standard under its principle of “Freedom to publish and to disseminate research results is preserved.” The guidelines state: “Consistent with current University policies, there should be no limits placed on the freedom to publish, except for short periods of delay that permit a sponsor to comment or to permit filing of patent applications.”