Institutional Conflicts of Interest

Institutional conflicts of interest can arise when the financial interests of an institution, or its senior officials, could potentially influence and bias institutional activities such as the allocation of resources, staffing decisions, the conduct of clinical practice, and the conduct and reporting of research findings. 

Academic centers can acquire financial interests and potential conflicts of interest through:

  • Earnings on intellectual property (IP)
  • Exclusive contracts with industry
  • Equity ownership in for-profit entities

The Financial Conflicts of Interest in Research policy outlines examples of what constitutes an Institutional Financial Interest:

  • Ownership by Mount Sinai of, or receipt by Mount Sinai through, its technology transfer activities of: 
    • Equity and ownership interests of any amount in a non-publicly traded, for-profit entity
    • Equity and ownership interests valued at more than $100,000 in a publicly traded, for-profit entity, excluding equity managed by Mount Sinai's Investment Committee
    • Prior calendar year gross revenue, resulting from technology transfer activities, greater than $100,000 per entity
    • Receipt by Mount Sinai, in the prior calendar year, through its Development Office of charitable donations greater than $100,000 from a commercial entity or foundation that sponsors research at Mount Sinai
  • Financial relationships of an Institutional Official (defined as: all Mount Sinai senior management with responsibility for overseeing research, including: Dean(s); President; Chairs; Institute Directors; and Division Chiefs; or Senior leadership of committees and departments involved in research), these include direct payments (e.g., consulting fees, royalties) greater than $25,000 annually from a commercial entity or foundation that sponsors research at Mount Sinai; or equity and ownership interests of any amount by an Institutional Official in a non-publicly traded, for-profit entity.