Research Misconduct Conflict of Interest SOP

Conflicts of interest in research misconduct proceedings exist when the personal, professional, or financial relationships of an individual involved in the proceedings may affect, or reasonably appear to affect, an individual’s ability to be impartial during the research misconduct proceedings. Perceived and actual conflicts of interest are treated identically under ACA-30.

Conflicts of interest include:

• Participation in the disputed research project
• Ongoing collaboration with the respondent or complainant, as evidenced by co-authored publications or shared grants  
• Respondent or PI of the disputed research is an immediate supervisor, direct report, close friend, or family member
• Certain non-financial interests, including participation in a project that is in direct competition with the disputed research
• Any other real or perceived conflict

Conflicts of interest do not include relationships as a mere colleague or acquaintance (e.g., employment in the same department/division, shared service on University committees, etc.).

Initial Screening

Research Integrity Office (RIO) staff are responsible for performing an initial screening for potential conflicts of interest between the respondent(s) and/or complainant(s) and all individuals who may participate in the inquiry or investigation, including committee members, the Research Integrity Standing Committee Chair, the RIO and all Research Integrity Office staff members, and the Deciding Official (DO).

Screening will include the following:

• IU website search: Perform a search of the potential committee member or institutional official on the university's website to identify any similarities in research interests or professional relationships with the complainant(s) or respondent(s).
• IU website name Search: Perform a search combining the names of the potential committee member or DO and the respondent(s) or complainant(s) on the university's website to identify any meaningful collaborations, publications, or supervisory relationships.
• Google search: Conduct an exact search match [e.g., “John” AND “Jane”] Google search of the potential committee member or DO and the respondent(s) or complainant(s) to identify any relevant connections.
• Grants Management Toolkit (GMT) search: Use the university's Grants Management Toolkit (GMT) to look up potential committee members and DO for any sponsored projects in common with the respondent(s) or complainant(s).
• Thesis query: If a graduate student's thesis is involved, query the university library system to identify dissertation committee members or acknowledgments linked to the potential committee member or DO.

Conflict of Interest Screening Form: The RIO will complete a Conflict-of-Interest Screening Form documenting the above within the case file.

COI self-attestation

• Upon appointment, investigation committee members will confirm in writing whether potential conflicts with any involved parties exist.
• All other parties, including the RIO and their staff, Research Integrity Standing Committee Chair, and DO, must immediately disclose any potential conflicts of interests upon learning specifics of the case.

If such conflicts are present, the individual shall recuse himself or herself from any investigative or decisional role in the case, including assessment, inquiry, or investigation procedures. 

• If any prospective committee member, including the Research Integrity Standing Committee Chair, at any point in the process presents a conflict of interest, that committee member shall be replaced.
• If the RIO has a conflict of interest, the Deputy RIO shall carry out the functions of the RIO under this Policy for the particular matter.
• If a member of the Research Integrity Office staff has a conflict of interest, that individual shall be recused from all discussions about the matter, including committee meetings.
• If the DO has a conflict of interest, the President shall name a replacement to carry out the functions of the DO under this Policy for the particular matter.
• Conflicts of interest on the part of deans or department chairs shall be dealt with by the DO.

If it becomes necessary to appoint any replacement during the course of the process, the new appointee shall be fully informed regarding earlier procedures and evidence secured, but the process shall not commence anew.

The RIO, in consultation with the DO, is responsible for resolving disagreements over what constitutes a conflict of interest, except in the case of alleged conflicts involving the DO, in which case the President is responsible.

• Screening will be documented via the Conflict-of-Interest Screening Form, to be included in the institutional record.
• All identified conflicts of interest and the steps taken to resolve them will be documented in the institutional record.
• The RIO and their staff will ensure that the documentation is complete and transparent, providing a clear record of how conflicts were managed.