COI for Faculty
I would like to start a company, become part-owner of a company, or become a consultant. What should I do?
- Contact firstname.lastname@example.org if you’d like to meet with SPARC about for guidance on this process and your COI obligations.
- You may also contact your dean’s office.
Update Your Disclosure
- Update your disclosure here once you incorporate your company or sign the consulting agreement.
- Your Dean's Office and SPARC will review your disclosure and determine whether a management plan is needed.
Sign a COI plan (if needed)
- Sign a COI management plan when direcred by your Dean's Office and/or SPARC.
- Click here for a sample management plan.
After your management plan is signed, here’s what happens next:
- The Faculty Conflicts Committee (FCC) will review your disclosure and plan. The FCC will either recommend the plan for final approval by the Provost, or request additional changes to the management plan.
- The Provost provides the final approval for management plans.
Throughout the year, here are your continuing obligations:
- As needed, update your disclosure for new activities.
- When submitting sponsored research proposals relating to your activity, ensure that the COI question in Cayuse is answered “Yes”
- When submitting manuscripts and giving presentations related to your activity, disclose your COI. Email email@example.com for sample disclosures you can include in such manuscripts and presentations.
- As new students and staff join your lab and research team, disclose your conflict to them in writing.
- Yearly, resubmit your COI disclosure during the annual disclosure season even if there are no changes in your activities with the outside company.
- Yearly, submit an annual recertification form as requested by SPARC or your dean’s office.
- Every four years, take COI training if you receive sponsored research funds
What are some best practices for managing my COI?
- Create a clear separation between company activities and your Rice activities
- Do not use Rice equipment and labs for company activities unless authorized under a sponsored research agreement or permission from your dean’s office and/or department. Otherwise, Rice facility use must comply with Policy 831 (“Stewardship and Personal Use of University Property”)
- Do not use your Rice email, address, and telephone number as the company contact.
- When negotiating a consulting agreement, negotiate a clear scope of work (“the development of enzyme abc and its uses in company’s technology xyz” is preferable to "research in biosciences")
- Be aware of the Conflict of Commitment Policy 216. Consult with your dean’s office if your activities require a greater level of commitment than the guidelines stated in Policy 216.
- Inform your dean’s office and/or firstname.lastname@example.org before engaging Rice students and staff in your activities with the company.
- For sponsored research funding, if Rice is the subcontractor for the company’s prime award, generally the same PI (e.g., the faculty member with a conflict) cannot be the named PI on both the prime and subcontract award. The same rule generally applies if Rice is the prime awardee and the company is a subcontractor.
What’s in a management plan?
- Here is a sample management plan.
- However, every situation is different, and additional elements to this plan may be necessary to mitigate the conflict. These additional elements can include:
- Monitoring of research and financial expenditures by independent reviewers;
- Modification of the research plan;
- Disqualification from participation in the portion of funded research that could be affected by the conflict of interest;
- Reduction or elimination of the Outside Interest (e.g., sale of an equity interest); and
- Severance of relationships that create conflicts.
I’d like to start a company with a student. What should I do?
The Offices of Research, Sponsored Projects and Research Compliance, and the deans of Engineering, Natural Sciences, and Graduate and Postdoctoral Studies, and the Faculty Conflicts Committee have developed the guidelines below for cases involving faculty members forming companies with their graduate student (Ph.D.-track) advisee form a company together. These guidelines are intended to balance the University’s interests in protecting the academic rights of graduate students and recognizing the benefits of student and faculty entrepreneurship. These guidelines are:
Graduate students (Ph.D.-track) may form companies with their faculty advisors, provided that:
- such participation does not conflict with the terms of their funding;
- they should have advanced to Ph.D. candidacy;
- they are not on academic probation;
- they separately disclose these activities to their deans and the Office of Sponsored Projects and Research Compliance; and
- students and their faculty advisors jointly sign conflict of interest management plans.
- Required oversight to be included in each management plan:
- Once a semester meeting with:
- A dean’s office representative; and
- EITHER (a) the Department Chair or (b) the department’s Director of Graduate Studies.
- Students are informed that they may seek additional guidance from the Office of Graduate and Postdoctoral Studies for COI questions and concerns
Please note that these guidelines typically apply to faculty member advisors and their Ph.D.-track graduate student advisees. Involving other students and research staff in one’s outside activities may require similar management elements.
Whom do I contact for COI questions?
- email@example.com, the Office of Sponsored Projects and Research Compliance
- Your dean’s office