Rush Institutional and Business Conflict of Interest
The mission of Rush is to improve the health of the individuals and diverse communities we serve through the integration of outstanding patient care, education, research and community partnerships. Collaboration is a core value supporting this mission. As Rush engages with external partners and outside entities, situations may arise where a potential conflict of interest needs to be identified and managed.
An Institutional Conflict of Interest (ICOI) occurs when the institution, or an institutional official, including their spouse or family member, has an external interest that could influence or appear to influence the institution’s research, education, clinical care, or business operations. ICOI’s are of particular concern when external interests, whether financial or otherwise, create the potential for inappropriate influence that could compromise the objectivity and integrity of Rush’s decisions related to research, clinical care, education, outreach, purchasing, and business.
Transparency around Institutional Conflict of Interest is essential to maintaining Rush’s trust, integrity and regulatory compliance. When ICOIs are not disclosed or managed, they can undermine public confidence, compromise institutional integrity and potentially lead to legal consequences. Rush established the ICOI Committee to ensure that actual and perceived ICOIs are addressed.
The Committee is responsible for reviewing disclosed external activities of individuals who hold fiduciary roles at Rush, such as board members, institutional officials, officers, or members of management acting within their authority on behalf of the institution. These roles may involve financial interests that could influence, or appear to influence, their duty of loyalty or duty of care in institutional decision-making
The Committee conducts conflict of interest (COI) assessments and when conflicts are identified the Committee oversees the management, reduction or elimination of the conflicts to help protect Rush’s organizational interests and mitigate the risk of private benefit and self-dealing.
NIH Regulations: The COI Office ensures compliance with all regulations and requirements set forth by the National Institutions of Health for Federally Funded Researchers. When a Financial Conflict of Interest (FCOI) is reported, the Rush COI Office is responsible for reporting it to the NIH. More information is available under COI Researchers.
Institutional Reporting Requirements to NIH
- Initial FCOI report: Includes the grant number, investigator, external entity, the nature and value of the financial interest and the associated management plan
- Ongoing FCOI reports: Includes required updates for previously reported conflicts
- Mitigation reports: Required when an FCOI is determined to have biased design, conduct or reporting of research
Disclosure of External Interests and Innovation
Disclosures of external interests and innovative related activities are made through the Rush Research Portal (RRP) by completing the Annual COI Survey.
Information and detailed instructions for completing the Annual COI Survey can be found here.
More information on COI Policies, can be found here.