New “Sunshine Act” requirements for disclosure by pharmaceutical and medical device companies of payments to faculty have led to increased conversation about conflict of interest (COI).1 Conflict of interest is defined as “circumstances that create a risk that professional judgments or actions regarding a primary interest will be unduly influenced by a secondary interest.”2 Conflict of interest is particularly relevant for those in the upper echelons of academic health system leadership—presidents, vice presidents, provosts, deans, chief executive officers, and the senior administrators who report to them.