November 16, 2012

Clarifications re: NSF Proposal Submission Requirements for FCOI



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.