Stanford faculty members owe their primary professional allegiance to the University, and their primary commitment of time and intellectual energies should be to the education, research, and scholarship programs of the institution. The specific responsibilities and professional activities that constitute an appropriate and primary commitment will differ across schools and departments, but they should be based on a general understanding between the faculty member and his or her department chair and school dean.

Even with such understandings in place, however, attempts of faculty to balance University responsibilities with external activities--such as consulting, public service, or pro bono work--can result in conflicts regarding allocation of time and energies. Conflicts of commitment usually involve issues of time allocation. Whenever an individual's outside professional activities (as defined in the RPH: Stanford’s Policy on Consulting and Other Outside Professional Activities) exceed the permitted limits (normally thirteen days per quarter), or whenever a full-time faculty member's primary professional loyalty is not to Stanford, a conflict of commitment exists.

Due to conflict of commitment concerns Stanford prohibits direction of a program of research or scholarship at another institution that could be conducted appropriately at Stanford (i.e. outside PI-ship).

If a situation that raises questions about a possible conflict of commitment arises, faculty should discuss the situation with their department chair or school dean, or with the Dean of Research.

Stanford policies concerning the outside professional activities of Stanford personnel include: Consulting and Other Outside Professional Activities By Members of the Academic Council and Medical Center Line Faculty, which applies to faculty; the Conflict of Commitment and Interest for Academic Staff policy; and the Staff Policy on Conflict of Commitment and Interest for all other staff. The staff policies only permit consulting with the written permission of the department/program chairman, by the principal investigator, or by the director of the appropriate library, relative to the specific appointment of the staff person.

In addition to the limit set on the time that a full-time faculty member may spend on outside consulting, Stanford's policy also prohibits:

• Management roles (activities or titles that constitute or imply managerial or supervisory responsibility); titles such as CEO, Director, Scientific Officer, or Vice President, etc. are designations generally assigned to people with line management responsibilities
• Ghost writing or publishing articles or other forms of scholarly communication under a faculty member’s own name in the course of an outside professional activity that are written in whole or material part by employees of the outside entity

All faculty investigators, and any other non-faculty participants in the research, who have responsibility for the design, conduct, or reporting of the research must disclose any personal financial interests that reasonably appear to be related to the project.

Personal financial interests in a company may reasonably appear to be related to the research/scholarship if that company/organization:

• Sponsors research at Stanford in which the investigator is directly involved
• Has financial interests that could reasonably be considered to have a potential influence on the design, conduct, or reporting of the investigator’s research/scholarship
• Has a reasonable possibility of being financially affected by the investigator’s research/scholarship
• Makes gifts to Stanford that benefit the investigator’s research/scholarship (including equipment gifts or loans)
• Makes a product that is under study in research in which the investigator is involved
• licenses Stanford intellectual property in which the investigator has a financial interest
• Has a Materials Transfer Agreement or Human Tissue Agreement (MTA/HTA) to provide materials used in the investigator’s research or for materials provided by the investigator to the company/organization
• Sponsors or makes a product that is under study in human subjects in which the investigator is directly or indirectly involved
• Has interests that are related to the investigator’s general scientific or scholarly expertise

The financial interest thresholds defined as significant financial interests (SFI) by the Public Health Service (PHS) (see here for further information) are as follows:

• Payments for services over $5,000/year or the ownership or promise of stock or stock options valued at $5,000 in a publicly traded company
• The ownership or promise of stock or stock options of any amount in a privately-held or start-up company
• Royalties over $5,000/year not paid through Stanford University

While most disclosures of financial interests will be deemed de minimus or not significant in terms of potential effects on the individual’s ability to perform his or her duties without risk of bias, financial interests above thresholds will automatically be deemed significant conflicts of interest and will require closer scrutiny and possible elimination, mitigation, and/or management.

If it is determined that a significant financial interest could have a direct and significant effect on the research, and/or the research on the financial interest, the conflict will need to be eliminated or managed according to a plan provided to the faculty member by the Cognizant dean for COI. Other administrative actions, such as disclosure in publications and public talks, may be required when the financial interest is not considered likely to directly and significantly affect performance of research.

Some common strategies for eliminating, mitigating, or managing conflicts include:

• Public disclosure of significant financial interests
• Training on conflicts of interest and commitment for all involved students and personnel
• Independent monitoring and oversight of the activity
• Modification of the Stanford research activity to remove the conflicted faculty member from participation in all or a portion of the research
• Divestiture of significant financial interests
• Other mitigating strategies

Education and guidance given to students by faculty, including the nature and direction of research or other studies, should be governed by what is in the academic interest of the student. In addition, personal financial interests should not influence the content of any educational activity or presentation at Stanford or elsewhere when given to students or the public, and any personal financial interests related to the educational activity should be disclosed. A financial interest in a company/organization could create a conflict of interest related to institutional responsibilities for education if that company/organization:

• Provides financial support for the faculty member’s trainees (students, graduate students, postdocs)
• Has products (excluding textbooks) or devices that are used in faculty member’s teaching
• Produces or markets distance learning services or materials in which the faculty member has an interest
• Supports faculty member’s participation as a lecturer/speaker in educational activities or on-line education programs

Such conflicts need to be disclosed and reviewed by the Dean, Cognizant dean, or COI Program administrator to ensure that such interests do not negatively affect students and trainees.

In addition, the School of Medicine has several specific policies addressing educational conflicts of interest. The policy on Commercial Support of Continuing Medical Education has prohibited the direct support of topic specific Continuing Medical Education (CME) by the commercial sector. See a link to the policy below in Related Items. Support from industry for CME will be considered only in the following general categories:

• medical, pediatric, and surgical specialties
• diagnostic and imaging technologies and disciplines
• health policy and disease prevention
• other broadly defined topic areas

The School of Medicine’s Stanford Industry Interactions Policy (SIIP) requires that non-CME educational activities supported by industry be designated for broadly defined areas only, not involve promotion or marketing, and that industry not influence the curriculum, among other things. Conflicts of interest must be disclosed to the learners.

Industry support for educational activities involving medical and graduate students and postdoctoral fellows and trainees must be approved by the Senior Associate Dean for Education.

SIIP also prohibits industry-sponsored "speakers bureaus” (i.e., contractual relationships to give talks in which the topic(s) and/or content are provided by the company) and dedicated marketing and training programs designed solely or predominantly for sales or marketing purposes.