Conflicts of Interest in Research
Federal and state funding agencies have a myriad of compliance requirements for all institutions receiving grant funding. Of these compliance requirements, perhaps none is as daunting to understand as the certifications regarding conflicts of interest. Several potential conflicts of interest may exist:
- Academic Conflict of Interest
- Conflicts of Commitment
- Financial Conflict of Interest
- Organizational Conflicts of Interest
While each type of conflict of interests must be carefully considered before, during, and after the grant submission, award, and management processes, for the purposes of this page, the main type of conflict of interest we will focus on is the Financial Conflict of Interest.
Policy and Procedure
Angelo State University’s policy and procedure applies to all faculty and staff who serve as the principal investigator, project director, or other senior/key personnel responsible for the development and conduct of a sponsored project.
What do I have to report?
In short, you must report any significant financial interests that might reasonably appear to be affected by your institutional responsibilities. Specific details regarding the types of interest and dollar thresholds are outlined in ASU’s Operating Policy 56.08.
What is a financial conflict of interest?
A number of definitions exist, but the most succinct comes from the latest revision of Title 42 of the Code of Federal Regulations*, which states that a “financial conflict of interest (FCOI) means a significant financial interest that could directly and significantly affect the design, conduct, or reporting of…research.”
Visit the links listed in the right-hand navigation to learn more about financial conflict of interest, including ASU’s policy, a brief tutorial, and other resources provided on external Websites.
*Source: Promoting Objectivity in Research, 42 C.F.R. pt. 50 (2011).
How often do I have to report?
Upon submitting a proposal for an externally sponsored grant, cooperative agreement, or contract and once a year thereafter. Additionally, if you gain a significant financial interest during the course of the year, you must report the new interest within 30 days of acquiring it.
How often do I have to attend training?
For individuals working on projects funded by the Public Health Service (PHS) or the Cancer Prevention and Research Institute of Texas (CPRIT), training must be completed once every four years or whenever the policy is revised, whichever comes first. Online training is available through ASU’s subscription to the CITI Program. Individuals needing to complete training should e-mail the Office of Sponsored Projects for more details on accessing the online course.
Numerous federal and private agencies have developed resources related to financial conflict of interest. For additional information regarding agency policies, frequently asked questions, and implementation of conflict of interest policies at other institutions, please visit the Websites listed below.
- National Science Foundation Policy on conflicts of interest
- 42 CFR 50: Promoting Objectivity in Research, applicable to all projects funded under the Public Health Service, including the NIH
- National Institutes of Health Tutorial on Financial Conflict of Interest
- Frequently Asked Questions about the NIH’s revised regulations
- Conflict of Interest Educational Materials from the Council on Government Relations
- U.S. Department of Education Policy on Conflict of Interest