Key personnel and "long distance" settings: determining who must report financial conflict of interest.

Conflicts of interest (COIs) can impact the integrity of scientific research. While public imagination has focused on scientists, regulatory discourse recognizes a broader range of individuals who might have financial COIs. This essay asks, for personnel who enroll subjects at a physical and organizational remove from the primary research team, whether reporting COI to an institutional review board or COI committee protects research integrity. After examining definitions of COI, regulations on COI, and rubrics for evaluating COI policies, we argue that requiring recruitment personnel who work at a distance from the primary research team to report potential COI protects neither research integrity nor human subjects.