What is an example of an institutional conflict of interest (COI)?

The answer

An institutional conflict of interest (ICOI) occurs when the financial or other interests of the institution itself — or of a senior institutional official acting on its behalf — could compromise, or appear to compromise, the objectivity, integrity, or safety of research conducted at that institution.

A classic worked example: a university owns equity (stock) in, or receives royalties or a large gift/grant from, a company, and that same company's drug, device, or product is being tested in a clinical trial run at the university. The institution now has a financial stake in the study producing favorable results. Even if every individual researcher is honest, the institution's interest creates a risk of bias and an appearance of impropriety — that is the institutional COI.

Other examples of institutional COIs include:

• A university holds a patent or license on the technology being evaluated in its own labs.
• A senior official (e.g., a dean, VP for research, or trustee) sits on the board of, or holds significant stock in, a company sponsoring research at the institution.
• The institution receives a substantial donation from a sponsor whose product is under study.

Institutional vs. individual COI

The key contrast the exam tests is institutional versus individual conflict of interest:

• An individual COI involves a single researcher's personal interests — for example, an investigator who owns stock in the drug company funding their study, receives consulting fees or speaking honoraria from it, or has a family member employed there.
• An institutional COI involves the organization's interests — the university's equity, royalties, patents, or the financial interests of senior officials who can influence institutional decisions.

So "a researcher personally owns stock in the sponsor" is an individual COI, while "the university owns stock in the sponsor" is an institutional COI. The distinction is who holds the competing interest — the person or the institution.

Why it matters and how it's managed

Institutional COIs are especially serious in human subjects research because the institution controls the very bodies meant to protect participants and ensure integrity — the IRB, the tech-transfer office, and research administration. If the institution stands to profit from a study's outcome, the impartiality of that oversight can be undermined, threatening both participant safety and public trust.

Management typically involves an institutional COI committee separate from the individual COI process. Strategies include disclosure of the interest, independent oversight or monitoring of the research, moving the study to another site, having the conflicted officials recuse themselves from related decisions, appointing independent IRB review, or in some cases divesting the financial interest. The guiding principle is transparency plus separation: those with the financial stake should not control the research or its oversight.