The University of Kansas encourages the development of new
technologies that advance scientific knowledge and contribute
to the public good. Researchers are encouraged to participate
in technology transfer activities including forming new start-up
companies based on newly discovered technologies. Additionally,
the University encourages and supports the transfer of University-developed
technology to commercial entities. Technology transfer is an
important outcome of the University's research and educational
efforts. To ensure that the mission of the University is not
compromised and that research integrity and objectivity is held
to the highest standards, an employee's outside activities with
regard to University research and transfer of the University's
technology must be disclosed, reviewed and managed with appropriate
oversight. To that end the University adopts the following policy:
- As early as practicable, a Principal Investigator (PI) without
conflict of interest will be recruited for research on technologies
in which the PI and/or the university hold a financial stake.
The university will enter into an agreement to allow the PI with a conflict of interest to continue such research if that PI can reasonably demonstrate the impracticability of recruiting
a qualified, alternative PI without a conflict of interest
and a management plan acceptable to the University is developed
and implemented.
- When feasible, clinical trials involving human subjects and
utilizing university discoveries also will be conducted at
other universities to minimize bias.
- If research under the inventor's direction does not potentially
benefit the company, then he/she is free to hold a seat on
that company's Board of Directors. Research is considered to
be under the inventor's direction if he/she is principal investigator,
or if he/she is department chairman or dean of the individuals
conducting the research.
- The Conflict of Interest Committee will determine which measures
may be appropriate to ensure data integrity and protection
of human subjects. Such measures may include the requirement
of oversight by a Data and Safety Monitoring Board and/or periodic
audits of the research by a disinterested party. Questions
regarding data safety will be referred to the Lawrence Campus
Human Subjects Committee until such time that a separate Data
Safety Monitoring Board is necessary.
- The University recognizes that, at times, the inventor will
be the only individual who is qualified to conduct research
on the new technology. In those cases, the following practices
will be employed to manage the potential conflict of interest:
- Ordinarily the inventor* will not sit on the company's
Board of Directors. From time to time, however, the inventor
may sit on the company's Board of Directors with the review
and approval of the Provost. In making this decision, the
Provost shall take into consideration factors such as the
protection of human subjects and protection of research integrity.
- If the inventor wishes to continue serving as PI for such
a research program and the inventor has a direct management
role in an entity Sponsor funding such research program,
a plan shall be developed with the overseeing Conflict of
Interest Committee and approved by the Vice Provost
for Research and Graduate Studies
for the inventor to transition out of the management role
as soon as practicable. This plan shall include measures
described in paragraph 4 above, including a Data Safety Monitoring
Board and/or periodic audits. For purposes of this policy,
a Sponsor is an entity external to the University of Kansas
that provides support (financial, in-kind, etc.) for a research
project.
- The inventor may retain equity interests in the start-up
company.
- The inventor may participate on the company's Scientific
Advisory Board. Inventors shall recuse themselves from decisions
by the Scientific Advisory Board that involve their research.
- Within the University's academic departments, inventors may
not make salary, promotion or tenure decisions for individuals
who participate in research relating to a University of Kansas
licensed technology where the inventor has a financial interest.
In such cases, inventors may make salary, promotion or tenure
recommendations only after disclosing the potential conflict
of interest to the person(s) responsible for making the salary,
promotion or tenure decision.
- Participation in the management of any company must comply
with the Regent's policy on Conflict of Time Commitment.
- When a licensee or a sublicensee uses University generated
data to support product development by a company that has licensed
University technology and/or in which the University has an
equity interest, the Conflict of Interest Committee shall examine
the relationship between the company and the licensee or sublicensee
(research sponsor). The Committee will make a determination
about whether a conflict of interest exists and, if it does,
will ensure that an appropriate management plan is in place.
- The University of Kansas Center for Research and the University
of Kansas Research Institute shall disclose the creation of
new technology companies to the Conflict of Interest Committees
on University campuses so that planning for technology development
and management of potential conflict of interest can be contemporaneous.
*Requirements of the inventor also apply to "immediate
family" as defined by Kansas Board of Regents Policy on
Conflict of Interest as well as designees of the inventor.
Questions? Please contact:
William Sharp
785-864-7430 | wsharp@ku.edu
Director | Research Integrity
— or —
Susan MacNally
785-864-4148 | sumac@ku.edu
Compliance Coordinator | Research Integrity
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