Conflict of Interest - Grants and Contracts 

Federal and State regulations require that Principal Investigators (PIs) and key project personnel complete a “Statement of Economic Interests” form upon application for non-governmental external funding. The Statement must be updated annually throughout the funding period.

For Federal funding, Federal regulations require that Principal Investigators disclose significant financial interests, including those of their spouse and dependent children, that would (1) reasonably appear to be affected by the research or educational activities receiving federal funding, or (2) in entities whose financial interests would reasonably appear to be affected by such activities. This disclosure must take place at the time a proposal is submitted, and be updated annually throughout the funding period.

New PHS and NIH regulations as of July 1, 2012, require changes that include decreased reporting thresholds, reporting reimbursed travel and require training.  A Supplemental Conflict of Interest Policy for PHS and NIH Grants and Contracts only, has been added to our existing policy.  All PHS and NIH Project Investigators (PIs) and key project personnel must complete training and adhere to the new Conflict of Interest regulations. 

Again, the new regulations affect only grants and contracts administered through the Department of Health and Human Services (DHHS), Public Health Service (PHS) and the National Institutes of Health (NIH).  Grants and contracts through the National Science Foundation, Department of Education (DoE), etc. are not affected.  

Please take a moment to ensure you have completed each of the following steps:

If you are a new Non-DHHS/PHS/NIH PI:

• Review the COI Policy for Non-DHHS/PHS/NIH Grants
• Complete the Conflict of Interest Disclosure Form (Governmental Non-DHHS/PHS/NIH)
• Complete the Conflict of Interest Disclosure Form (Non-Governmental Funding Source)
• Plus complete the instructions below

If you are a new PI or a current PI with a DHHS/PHS/NIH Grant:

• Review the NIH Training Tutorial (no sound); Please complete the Certificate of Completion at the end of the training and return it along with the other required documents to the Office of Sponsonred Projects
• Review the Supplemental COI Policy for DHHS/PHS/NIH Grants and Contracts
• Complete the Conflict of Interest Disclosure Form (Governmental DHHS/PHS/NIH Grants)
• Complete the Conflict of Interest Principal Investigator Certification

Please return all completed forms to the Office of Sponsored Projects at the UARSC Office via intercampus mail or in person.