Conflict of Interest (COI)

NMU encourages faculty and staff to participate in non-NMU activities that involve expertise or intellectual property that is shared with the private sector. The NMU Conflict of Interest (COI) policy and procedures exist so that NMU can appropriately manage any potential conflicts of interest when a faculty or staff members' activities or collaborations outside of their NMU are funded with extramural funds. NMU also requires PIs to complete COI training via the CITI program. Information about policies and procedures for managing Financial Conflicts of Interest (FCOI) among various agencies is listed below.

PHS-defined financial conflict: A PHS-funded investigator who has significant financial interests that could lead an independent observer to reasonably question whether the design, conduct, or reporting of research might be influenced by the possibility of personal gain to the individual or his or her immediate family (i.e., spouse and dependent children)

  • PHS regulations on Responsibility of Applicants for Promoting Objectivity in Research (42 C.F.R. Part 50, Subpart F)
  • Responsible Prospective Contractors (45 C.F.R. Part 94).

These regulations promote objectivity in research by establishing standards that provide a reasonable expectation that the design, conduct, and reporting of research funded under PHS grants or cooperative agreements will be free from bias resulting from investigator financial conflicts of interest.

NMU Requirement: All NMU researchers who participate in Public Health Service (PHS)-funded research must fully disclose potential FCOI (Financial Conflicts of Interest Disclosure Form) and successfully complete financial conflict of interest training through CITI. The FCOI Disclosure Form must be completed at the time of application for PHS funding, or within 30 days of discovering/acquiring a financial interest, and annually during the period of performance of a PHS award. Completed FCOI Disclosure Forms must be submitted to the Office of Research & Sponsored Programs.

NSF defines FCOI as significant financial interests of the investigator (including those of the investigator’s spouse and dependent children) that would reasonably appear to be affected by the research or educational activities funded or proposed for funding by NSF or in entities whose financial interests would reasonably appear to be affected by such activities. NSF awardees must:

  • maintain a procedure for managing how financial conflicts are reduced or eliminated prior to expenditure of award funds
  • take reasonable steps to ensure that collaborating entities (subawardees, contractors and collaborators) meet NSF FCOI requirements.

NMU Requirement: All NMU researchers pursuing NSF-funded research must fully disclose potential FCOI (Financial Conflicts of Interest Disclosure Form) and successfully complete financial conflict of interest training through CITI. The FCOI Disclosure Form must be completed at the time of application for NSF funding, or within 30 days of discovering/acquiring a financial interest, and annually during the period of performance of an NSF award. Completed FCOI Disclosure Forms must be submitted to the Office of Research & Sponsored Programs.

If an investigator or ORSP staff member suspects a potential FCOI, the Disclosure Form is submitted to the investigator’s Department Chair (or equivalent) and Dean for review and a meeting is convened with all parties to clarify information and gather documentation. If a FCOI is established, an ad-hoc committee will be convened to make recommendations and a plan to manage, reduce or eliminate the FCOI.