A conflict of interest is when a University employee is in a position to influence the conduct of a project for personal gain due to responsibilities or to arrangements with an outside entity. A conflict of interest (COI) situation is created by the combination of an external entity, your activity/relationship with that external entity, and your University employment/job responsibilites and activities. Conflict of Interest regulations apply to proposals and projects with the National Science Foundation (NSF), Public Health Service and the National Institutes of Health (NIH/PHS), and non-governmental agencies as prescribed by the California Fair Political Practices Commission. Investigators intending to conduct research funded by NSF or NIH/PHS should carefully review Sonoma State University's campus policy on Conflict of Interest: Funds Awarded by the National Science Foundation and the Public Health Service Policy.
SSU Policy Highlights
- The policy complies with federal, state and CSU requirements.
- An addendum added in 2012 complies with the requirements of the PHS and NIH.
- The policy requires faculty and other key personnel for PHS/NIH proposals and awards to comply with training requirements issued by PHS/NIH.
Introduction to COI Regulations and Disclosures
For NSF awards, NSF requires each grantee institution employing more than fifty persons to maintain an appropriate written and enforced policy on conflict of interest. Investigators must disclose all significant financial interests of the investigator (including those of the investigator’s spouse and dependent children)
- that would reasonably appear to be affected by the research or educational activities funded or proposed for funding by NSF; or
- in entities, whose financial interests would reasonably appear to be affected by such activities.
For PHS/NIH proposals and projects, the 2011 revised regulation promotes objectivity in research by establishing standards that provide a reasonable expectation that the design, conduct, and reporting of research performed under NIH grants or cooperative agreements will be free from bias resulting from Investigator financial conflicts of interest. The 2011 regulations:
- Require investigators to disclose to their institutions all of their significant financial interests related to their institutional responsibilities.
- Lower the monetary threshold at which significant financial interests require disclosure, generally from $10,000 to $5,000.
- Require institutions to report to the PHS awarding component additional information on identified financial conflicts of interest and how they are being managed.
- Require institutions to make certain information accessible to the public concerning identified SFIs held by senior/key personnel.
- Require investigators to complete training related to the regulations and their institution’s financial conflict of interest policy.
The FPPC is responsible for administering and enforcing the Political Reform Act (the Act). It enacts regulations that implement the law, issues advice letters, and adopts advisory opinions that apply the Act as well as the regulations to particular circumstances.
Specifically, Principal Investigators and Project Directors are required to disclose any conflict of interest code in connection with a decision made by a person or persons at an institution of higher education with principal responsibility for a research project to undertake such research, if it is to be funded or supported, in whole or in part by:
- A contract or grant from a nongovernmental entity sponsor, or
- Other funds from a nongovernmental entity earmarked by the donor for a specific research project or for a specific researcher.
Federal, State, and CSU Policy Guidance
- NSF Conflicts of Interest Policy
- PHS/NIH Financial Conflict of Interest Policy
- California Fair Political Practices Commission Conflicts of Interest Rules
- CSU Conflict of Interest Code
How to Submit a COI Disclosure(s)
Disclosure forms for proposals must be included with your proposal documents. Regulations require that a responsible official evaluate COI disclosure forms to determine if any disclosed conflicts require further action by SSU. Please access and complete the required disclosure form.
Required COI training for PHS/NIH Proposals and Awards
The 2011 PHS/NIH conflict of interest regulations require Principal Investigators and other key project personnel to complete COI training. SSU has subscribed to the Collaboration Institutional Training Initiative (CITI) to provide this training. Principal investigators and other key project personnel must complete this training at the time the proposal is submitted. Instructions for registering with CITI are provided but you may also contact your Project Administrator for additional guidance.
FPPC regulations also require training which is administered by Human Resources. You will receive notification for your required training from Human Resources.