Please
note the following clarifications regarding financial conflict of interest
(FCOI) disclosure requirements and procedures for National Science
Foundation (NSF) funding.
EXTERNAL
INVESTIGATORS
Per
the definition of “Investigator” as promulgated in the NSF
Conflict of Interest Policies, MU will not require reporting nor manage
the conflicts of external Investigators on NSF-funded projects. External
Investigators (e.g., non-MU co-PI, non-MU Collaborator) should be listed on the
Investigator Form; however, individual disclosures or institutional
certifications are not required.
PRELIMINARY
PROPOSALS
Preliminary
proposals (pre-proposals) utilize the NSF Proposal Cover Sheet and are thus
submissions subject to the Proposal
Certifications outlined therein. An Investigator Form is required for pre-proposal
submissions, and NSF pre-proposals will not be submitted until it is
confirmed that all MU Investigators have a current Outside Interest Disclosure
Form (OIDF) on file.
The
OSPA Sponsored Programs Procedure Guide (SPPG) will be updated to reflect these
changes. Should you have any questions or concerns, please don’t hesitate to
contact me.
In
light of the policy and procedure changes resulting from the 2011
Revised Federal Regulation on Financial Conflict of Interest, OSPA and the
COI Office have taken a closer look at the National Science
Foundation (NSF) Conflict of Interest Policies in relation to UM
CCR 420.030. As a result, the following requirement, currently applicable
to PHS proposals, will be in effect for NSF proposals as of Monday, November
12, 2012:
·
Proposals will not be submitted until it is confirmed
that all MU Investigators have a current Outside Interest Disclosure Form
(OIDF) on file and that required certifications are received for non-MU
Investigators.
An Investigator Form is required for all NSF
submissions. As a reminder, the Investigator Form initiates the Departmental
and OSPA review for required OIDFs and so should be completed and submitted to
OSPA well in advance of the submission deadline. Please watch for a separate
email this afternoon announcing a revised Investigator Form.
Requirements
at award, as described in the attached email, remain the same:
·
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
PHS and NSF policies differ in subtle ways, primarily with regard to COIC
review and reporting FCOIs to the sponsor. From the PI and Departmental
perspective, however, the procedures are essentially the same as of
11-12-2012. We will continue to communicate clarifications as we receive
additional guidance from sponsor agencies implementing COI regulations and
policies.
The
OSPA Sponsored Programs Procedure Guide (SPPG) will be updated to reflect these
changes. Should you have any questions or concerns, please don’t hesitate to
contact me.