NSF and Conflict of Interest

The COI Office and OSPA have clarified requirements and processes for National Science Foundation (NSF) proposals and awards related to conflict of interest (COI).

At Proposal

Because the NSF policy differs from the PHS regulation*, procedures as proposal will accordingly differ:

·         Following an NSF proposal submission, the COI Office will contact the PI directly (with a copy to Department and OSPA pre-award staff) to identify Investigators (as defined by NSF), confirm all required Outside Interest Disclosure Forms are current, and guide the process of completing Conflict of Interest Training. Note: Per University of Missouri policy, Conflict of Interest Training is mandatory prior to expenditure of funds, should the proposal be awarded.

     For NSF proposals currently in process: Investigator Forms and/or NIH-NSF Financial Disclosure Forms currently received or in process for upcoming NSF proposal submissions are now not required but are certainly not wasted effort. Please submit to your SGCA who will, in turn, include the information when alerting the COI Office to the proposal submission. The PI should still expect an email from the COI Office.  

At Award

·         The OSPA SGCA will work with the COI Office to ensure the required reviews, which include confirmation that all NSF Investigators on the project have completed mandatory Conflict of Interest Training. Upon notification from the COI Office that the reviews are complete (and with all other approvals and certifications in place), the SGCA will set up the award and distribute the Grant Award Summary.  

*The NSF Conflict of Interest Policies are less exacting in their timing requirement for financial disclosures. For the purposes of MU’s COI policy and procedures, “at the time the proposal is submitted” includes the post-submission period prior to award. Recall that, in the past, OSPA would not stop a submission if an NIH-NSF Financial Disclosure Form was outstanding but would follow up thereafter to ensure all required forms were on file within a reasonable period of time. With the COI Office now overseeing all disclosures through eCompliance, the same line of reasoning applies.  

This is not the case for PHS per the 2011 Revised Federal Regulation on Financial Conflict of Interest, where disclosure is unequivocally mandatory prior to proposal submission: 

Please take note of the COI Office presentations scheduled for Tuesday, September 18, and Monday, September 24 (see attached). I will be in attendance should you have questions about related OSPA procedures. 

                                                                                                                                               

Research Community,

The Public Health and Services (PHS), which includes the National Institutes of Health (NIH) and the Food and Drug Administration (FDA), has revised the regulations that govern Conflict of Interest (COI).  The regulation has new requirements for both MU as a PHS-funded Institution and the Investigators who work on those projects.  Implementation of these new processes began on August 24, 2012.  The COI Office is taking the lead on ensuring these regulations are met. 

We will be giving a detailed presentation about the new Investigator responsibilities for all Investigators and Staff who are interested.   This is especially important if you currently have PHS funded research or anticipate receiving PHS funding.  If you did not attend the session offered over the summer, please plan to attend one of the following times in the Monsanto Auditorium, Bond Life Sciences Center:

• Tuesday, September 18, 2012 from 9-11am
• Monday, September 24, 2012 from 1-3pm 

Please feel free to forward this email as you deem appropriate.  If you have any immediate questions about how these changes will impact your role in the research award process, or if you would like a more detailed presentation of the changes for your department specifically, please contact the COI Office at: 884-3317 or coi@missouri.edu. 

Below is a summary of the changes that impact Investigators and the proposal/award process. 

At Proposal-

• PIs must submit a form identifying all Investigators for each PHS or NSF project.
• This form will replace the previous COI form used on these projects and is available through OSPA or your Departmental Grants Administrator. 
• BEFORE the proposal can be submitted, all Investigators listed on the form must have a current COI form submitted within the previous 12 months. NO PHS proposals will be submitted until OSPA can verify that all Investigators have filed a current COI form.  
• All Subcontractors on PHS-funded proposals must certify by way of the Subrecipient Commitment Form that the institution/organization has a publicly accessible COI policy that complies with the PHS regulation and will timely submit required reports to MU as appropriate.  MU is not currently permitted to accept a subcontractor who will not make this certification. 

All Investigators, including the PI, listed on a project at proposal will be contacted after the submission to inform them about the requirements that need to be completed prior to the expenditure of funds. 

At Award-

PRIOR TO THE EXPENDITURE OF FUNDS (including pre-award spending accounts and spending under expanded authorities) the following must occur:

¡  The Conflict of Interest Committee (COIC) must review and determine whether any outside interests of the Investigators impact the project.

§  If yes: A management plan must be created and approved by the COIC, Investigator, Department Chair, and Dean.  A Financial Conflict of Interest report must then be submitted to PHS. 

¡  All Investigators must complete COI training through eCompliance: https://ecompliance.missouri.edu/training/10000-conflict-of-interest-training 

¡  All Investigators must report all Sponsored Travel related to their institutional responsibilities within 30 days of the trip through eCompliance.  Sponsored Travel is any travel paid for by an entity other than MU. https://ecompliance.missouri.edu/forms/10145-sponsored-travel-report/documents/new

¡  All Investigators must update their Outside Interest Disclosure Form (OIDF) within 30 days of acquiring or discovering new outside interests or sponsored travel not previously disclosed.

During an ongoing PHS-funded project-

• BEFORE a new Investigator may be added to a project, he/she MUST complete all the above requirements.  Notify the COI Office before adding personnel to PHS-funded projects. 

As mentioned above, please plan to attend this presentation to learn more about this process.  If your department would like a more detailed presentation about these changes, please contact the COI Office to set up a time.  Please call if you have any other questions or concerns.