Conflict of Interest (COI)

A conflict of interest is a set of circumstances that creates a risk that professional judgment or actions regarding a primary interest will be unduly influenced by a secondary interest.

Should you have any questions on the conflict of interest/conflict of commitment policies, procedures or regulations, please do not hesitate to contact:
Stephanie Pena, Director of Institutional Compliance & Ethics, at x9880 or via email at spena4@umassd.edu.

Conflict of Interest

Faculty Requirements for Outside Activities

The Dartmouth campus requires an annual disclosure from all faculty members regarding Outside Activities as defined in Trustee Policy T96-047.

Government, Foundation, Industry Funded Researchers

This form is required to be filed for every proposal to private foundations, industry and any government entity that has not adopted PHS/NIH or NSF policies. Please submit it with the Proposal Routing Form (PRF). It is required for all Investigators and any other person who is responsible for the design, conduct, or reporting of the research. If an Investigator has a reportable financial interest, it must be disclosed to SPA when the Investigator submits the relevant grant proposal and whenever a reportable financial interest arises during the period of an award.

PHS (Public Health Service Agency) Funded Researchers

The U.S. Public Health Service (PHS) amended its Financial Conflict of Interest (FCOI) Regulations effective August 24, 2012. These regulations have unique reporting and conflict management requirements and require an initial disclosure of all financial interest related to the institutional responsibilities of the investigator to the Office of Sponsored Programs Administration.

The PHS Summary Disclosure Form is required for proposals to: Office of Global Affairs (OG); Office of the Assistant Secretary for Health (OASH); Office of the Assistant Secretary for Preparedness and Response (ASPR); Agency for Health Care Research & Quality (AHRQ); Agency for Toxic Substances and Disease Registry (ATSDR); Centers for Disease Control and Prevention (CDC); Food and Drug Administration (FDA); Health Resources and Services Administration (HRSA); Indian Health Service (IHS); National Institutes of Health (NIH); Substance Abuse and Mental Health Services Administration (SAMHSA); Alliance for Lupus Research (ALR); American Asthma Foundation; American Cancer Society (ACS); American Heart Association (AHA); American Lung Association (ALA); Arthritis Foundation (AF); CurePSP; Juvenile Diabetes Research Foundation (JDRF); Lupus Foundation of America (LFA); Patient-Centered Outcomes Research Institute (PCORI); Susan G. Komen for the Cure

PHS regulations require investigators to undergo COI training every four years. Training is provided through www.citiprogram.org. Select "complete conflict of interest training." There are two required modules: (1) Financial Conflicts of Interest: Overview, Investigator Responsibilities, and COI Rules (COI-Basic) (ID: 15070) and (2) Institutional Responsibilities as They Affect Investigators (COI-Basic) (ID: 15072).

NSF (National Science Foundation) Funded Researchers

Faculty investigators who are supported by external funding from the National Science Foundation (NSF) and other federal agencies adopting the NSF requirement, must submit a NSF summary disclosure form with each proposal. The summary disclosure form must be updated whenever an investigator obtains new reportable significant financial interests.