University of California, Santa Barbara
IN-1: Academy-Industry Connections

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):
University 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):
University 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://policy.ucop.edu/doc/2500633/NSFCOIDisclosure

- 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:
University policy states: “It requires that PIs use the Form 700-U to disclose whether they have a Financial Interest in the research sponsor, if that research is funded or supported, in whole or in part, by a non-governmental entity (a) through a contract or grant, (b) by a gift which is designated by the gift donor for a specific research project, or a specific Principal Investigator, or a laboratory or research program headed by a Principal Investigator, or (c) through in-kind support provided under a material transfer agreement (MTA).”
Specific details of the policy can be accessed here: https://policy.ucop.edu/doc/2000678/COI-700-U .

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.

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.
The policy guidelines linked from this page - https://www.ucop.edu/research-policy-analysis-coordination/policies-guidance/future-research-results/index.htm explicitly prohibit this type of arrangement: https://www.ucop.edu/research-policy-analysis-coordination/_files/Principles%20Guidelines.pdf Page 7 "The University also has a commitment to make the results of its research widely available for the public benefit through publication, open distribution of TRPs (tangible research products) for verification and use in ongoing research, and a reserved right in licenses of University intellectual property for other non-profit research institutions to practice such intellectual property for research and educational purposes. "

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.”