University of Southern California
IN-1: Academy-Industry Connections

USC has several policies that cover conflicts of interest and the review processes for each type of conflict. They are summarized below:

The broadest policy is the Conflict of Interest and Commitment policy which applies to all USC employees and students.

USC’s Conflict of Interest in Research policy contains additional conflict of interest requirements specific to research activity, and applies to USC employees and students involved in proposing, conducting, and/or reporting research.

USC’s Relationships with Industry policy contains additional Conflict of Interest requirements specific to the provision of healthcare and applies to USC Employees and students who are healthcare professionals.

USC’s Institutional Conflict of Interest in Research Policy covers institutional conflicts of interest related to research.

Per the COI in Research policy: Investigators are not permitted to begin any research activity when there is an actual or apparent conflict of interest before they receive a written determination from the Vice President of Research as to how to manage the conflict. Prior to this determination, all research conflicts of interest are reviewed by one of two standing committees.

This policy covers consulting payments as well as other outside financial interests:

Payments for Services

Payments for services from a research sponsor or an entity that may benefit economically from the outcome of the research that total $5,000 or more when aggregated over a twelve-month period must be disclosed. This includes but is not limited to payments for:

Service on a board, advisory committee, or review panel
Scientific or technical appointments
Payments for lectures and similar public appearances
Honoraria
Paid authorship
Consulting

The Relationship with Industry Policy also covers consulting payments specifically:

A.1 Requirements for Consulting Arrangements
A.1.1 USC Healthcare Professionals are ultimately responsible to ensure that all Consulting Arrangements:

Are in writing; and
Describe in reasonable detail the services provided by USC Healthcare Professionals; and
Provide no more than fair-market compensation; and
Require necessary and legitimate services that are actually rendered; and
Are not entered into for longer than a one year term and with extensions being treated as new agreements requiring compliance with all sections of Section A; and
Are not motivated (or appear to be motivated) by any improper purpose, such as to incentivize the USC Healthcare Professional to change or maintain his or her purchasing or prescribing habits; and
Are not provided at a time when the USC Healthcare Professional is otherwise engaged in University activities, such as the provision of healthcare; and
Comply with the USC Faculty Handbook on Outside Consulting and the USC Conflicts of Interest in Ethics Policy and Procedure; and
Are submitted in advance for review and approval prior to agreeing to, engaging in, or accepting reimbursement for the consulting activities; and
If the consulting arrangement is related in any way to a company where the USC Healthcare Professional is also involved in a sponsored research project, the
USC Healthcare Professional has completed and submitted a Statement of Outside Interests under USC’s Conflict of Interest in Research Policy.

A.1.2 In addition, before signing a Consulting Arrangement, USC Healthcare Professionals should consider whether the request for services has originated from an appropriate unit/division within Industry. For example, Industry marketing representatives generally are not the appropriate unit to engage services that are solely scientific in nature.

The Conflict of Interest and Commitment Policy can be found here: https://policy.usc.edu/conflict-of-interest-and-commitment/

The Conflict of Interest and Research Policy can be found here:
https://policy.usc.edu/conflict-of-interest-in-research/

The Relationship with Industry Policy can be found here:
https://policy.usc.edu/industry-relationships/

The Institutional Conflict of Interest in Research policy can be found here: https://policy.usc.edu/institutional-research-conflict-interest/

The Association of American Medical Colleges defines ghostwriting as “the provision of written material that is officially credited to someone other than the writer(s) of the material.” Transparent writing collaboration with attribution between academic and industry investigators, medical writers and/or technical experts is not ghostwriting. It is not permissible for USC Healthcare Professionals, students or trainees to allow their professional presentations to be ghostwritten by any party.

More information: https://policy.usc.edu/industry-relationships/

USC generally does not restrict participation in research to United States citizens, nor does it accept restrictions on a researcher’s ability to share the results of his or her research freely and will only consider such projects on an exception basis. USC employees are required to submit a request for exception to the Office of Research if they become aware that a sponsor is seeking to restrict participation by a researcher, staff person, or student on the basis of nationality, or restrict publication (other than short review periods to ensure that no confidential or proprietary information has been inadvertently disclosed in an intended publication).

More information: https://ooc.usc.edu/wp-content/uploads/2022/10/Guide-to-Research-Fall-2022.pdf

All faculty-initiated proposals relating to research or training programs, whether made to private foundations, corporations, or government sponsors, must be transmitted to the prospective sponsor through regular USC channels, including the Department of Contracts and Grants. Approaches to private sources of funding for gifts must be coordinated with the Office of the Senior Vice-President, University Advancement, as well as submitted to the dean or Provost. See the University policies website (Website Link: http://policy.usc.edu). All proposals for sponsored research or training programs should utilize the TARA system to document approvals by academic and administrative officers before submission to the Department of Contract and Grants. These should be prepared as far in advance of submission dates or deadlines as possible. For more information on the preparation process, please consult the Department of Contracts and Grants website (Website Link: http://research.usc.edu/dcg).

The University policy regarding participation in classified or proprietary research is not to accept or to renew extramural contracts, grants, gifts or other agreements that restrict the rights of the faculty to free conduct of inquiry or to free scholarly dissemination of results within a reasonable time, with the exception of the limited cases.

More information: https://policy.usc.edu/wp-content/uploads/2022/10/Faculty-Handbook-2022.pdf

The proposal process for all sponsored research, including industry sponsored research, is detailed in the USC Guide to Research:
https://ooc.usc.edu/wp-content/uploads/2022/10/Guide-to-Research-Fall-2022.pdf

Additional data sources:
- https://ooc.usc.edu/wp-content/uploads/2022/10/Guide-to-Research-Fall-2022.pdf
- https://policy.usc.edu/wp-content/uploads/2022/10/Faculty-Handbook-2022.pdf
- https://policy.usc.edu/conflict-of-interest-in-professional-and-business-practices-2/
- https://policy.usc.edu/conflict-of-interest-in-research/