The purpose of this page is to provide guidance on the requirements for public disclosure of outside interests when required in the management plan approved by the Duke Conflict of Interest Committee (COIC). Public disclosure is encouraged regardless of whether a relationship rises to the level of requiring a management plan.
Public disclosure is a management plan element that serves to protect investigators and Duke University against accusations of malfeasance by identifying potential dual or competing interests that an investigator may have or appear to have in relation to their research. Providing full disclosure helps dispel the belief that a financial (or other interest) is purposely being hidden from the public.
When is public disclosure required?
Public disclosure is required if research is in any way related to your outside interests (or could be perceived to be related). The following can help to determine if research is related to outside interests:
- The research is fully or partially sponsored by a company in which you have a financial interest
- The research involves technology owned by or licensed to a company in which you have a financial interest
- The outcome of the research could or “appears” to affect the company in which you have a financial interest
- The outcome of the research could or “could appear to” negatively affect competitors of the company in which you have a financial interes
Public disclosure of financial interests is required in any public presentation of data from research related to (or appears to be related to) an outside interest. It is the responsibility of each author/presenter with a financial interest to ensure public disclosures are included in relevant publications and presentations.
*Public presentations include conferences, lectures, and any other speaking engagements, journal articles, including review articles, letters to the editor, etc.
How is the public disclosure statement to be incorporated into presentation materials?
A public disclosure statement should be included in any journal article, PowerPoint or other presentation slides or documents, posters, etc. presenting research related to the potential conflict as described above.
- Investigators should follow the journal or scientific organization's policy for submission of financial disclosure information.
- If the journal or meeting host does not have a policy, the investigator should include a disclosure of their financial interests in a letter to the editor or meeting organizer.
- The disclosure statement may be placed in any location in the article, slide, or poster presentation as preferred. It only needs to be included in one location (not on every slide).
What if the journal or scientific meeting host's financial disclosure requirements are different than Duke's?
As long as public disclosure occurs, the exact wording and placement of that disclosure is negotiable.
What could happen if an investigator fails to include a public disclosure statement as required?
Investigators maybe required to contact the journal to publish an erratum for any missing or inadequate disclosure statement noted by the conflict of interest office. The office recommends that investigators confirm with the publisher, immediately before publication, that the correct disclosure statement is present. Additional corrective actions may be required for non-compliance with management plans.
Investigators are encouraged to contact the COI office (firstname.lastname@example.org) with any questions about disclosure requirements and whether disclosure is required in a particular case that might fall into a "gray area", or to discuss how conflict of interest issues are being managed at Duke University.
Sample Journal and Professional Organization COI policies:
- American Society of Clinical Oncology
- New England Journal of Medicine
- The lancet