COI Advisory Memo

Things to keep in mind related to Outside Activities and Interests:

  • You should maintain separation between your Duke responsibilities and your work with external entities.
  • It is not legal to use Duke’s name or non-profit resources to advance the commercial prospects of a for-profit entity.
  • Time dedicated to Outside Activities should be limited to the maximum allowed by the Faculty Handbook (See Chapter 5, page 15). Staff should consult with their immediate Supervisor.
  • Each of the following represents a significant financial interest (SFI) that carries Principal Investigator (PI) restrictions unless approved in advance when related to projects and protocols (research at Duke):
    • Having equity in a private company/entity (any amount);
    • Receiving income >$50K from any entity;
    • Stock ownership >$50K in value;
    • Equity/Stock options (any amount);
    • Projects/protocols involving optioned/licensed Intellectual Property (IP).
  • It is important to involve DOSI-COI in discussions at the time projects are being planned when a SFI is present.
  • You must not disclose non-public or confidential research information to any for-profit entity except as allowed by agreements executed through the University. 
  • Always disclose Outside Interests internally and externally. Disclosure is recommended when the objectivity of your research, presentations/publications, or other decisions (i.e. purchasing) may be called into question if you do not volunteer the information.
  • Disclose your Outside Interests to each student, fellow, or staff person whom you supervise when their work or degree could be related to one or more of your Outside Interests.
  • All outside professional activities that may involve a non-faculty member of the Duke community working with a Duke faculty member and reporting to that Duke faculty member as part of their primary commitment requires review and approval by:
    • the appropriate Dean(s), including of the graduate or undergraduate school as applicable if the non-faculty member is in a student/trainee role.
    • the department chair, if the non-faculty member is an employee of the University.
  • When listed as key personnel on a proposal related to an Outside Interest, the electronic grant attestation should reference the company/entity name and describe the relationship.
  • Any Duke work related to an outside entity must be performed under a Sponsored Research Agreement regardless of the funding source.
  • Duke policy limits participation in Speaker Bureaus and non-CME lectures and video/audio productions.  Participation in these promotional medical education activities is only allowed if certain criteria are met.  For more information you may access the Duke speaking policy at https://dosi.duke.edu/sites/default/files/atoms/files/Policy-Governing-Promotional-Medical-Education.pdf.
  • Remember to disclose Outside Interests as appropriate on Other Support and BioSketch documents.
  • Please keep in mind the continued concerns regarding undue influence on federally-funded research by foreign entities. Failure to disclose foreign activities and relationships may jeopardize eligibility for future federal funding to Duke University.
  • If you are federally funded, you must report many types of externally sponsored travel. Report sponsored travel and review FAQs at https://radapps.duke.edu/sponsored_travel.
  • Remember to update your COI Form within 30 days of any changes to your Outside Interests.

UPDATED 12/20/2022