Conflicts of Interest
Financial Conflicts of Interest
The University requires that investigators disclose any significant financial interest
of the
investigator (including those of the spouse and dependent children) that would
reasonably appear to be affected by the research or educational activities. This is
compliant with specific requirements of the National Science Foundation and the Public
Health Service regarding investigator financial conflict of interest and objectivity
in
research.
Please note that financial conflicts of interest do not prohibit research or funding,
as
long as they are properly disclosed and managed.
Disclosure
Please refer to the Office of Research Integrity website for detailed guidance on
Conflicts of Interest and the disclosure process. In addition, investigators must
certify by
signature on the Routing for Proposal Approval & Submission (RPAS) Form that s/he
has read and understands the University’s guidelines on Conflict of Interest in
Sponsored Programs and that all required financial disclosures have been made as part
of the proposal preparation and submission process.
Training
All Investigators engaged in research related to any PHS-funded grant or contract
must
complete COI training prior to engaging in research and at least every four
years. Training is available from UAF's Office of Research Integrity.
Disclosure to NSF and PHS
For National Science Foundation proposals, prior to expenditure of any funds under
the
award, the University will report to the NSF Office of General Counsel any conflicts
of
interest that cannot be satisfactorily managed, reduced or eliminated, but not the
nature
of the conflicting interest or other details.
For Public Health Service proposals, prior to expenditure of any funds under the award,
the University will report the existence of a conflicting interest to the PHS awarding
component, but not the nature of the interest or other details and assure that the
interest
has been managed reduced or eliminated.
Proposers to the National Science Foundation are often required to provide a Conflict of Interest Matrix. This matrix is not limited to financial conflicts of interest, but rather addresses potential conflicts of interest with reviewers who might be biased through their relationship with the investigator. All PIs will have reviewer conflicts of interest to disclose per the NSF guidelines:
"Proposals must include a conflicts of interest table, in the single copy documents section of FastLane, as a list in a single alphabetized table, with the full names and institutional affiliations of all people with conflicts of interest for all senior personnel (PI and co-PIs) and any named personnel whose salary is requested in the project budget. Conflicts to be identified are (1) Ph.D. thesis advisors or advisees, (2) collaborators or co-authors, including postdoctoral researchers, for the past 48 months, and (3) any other individuals with whom or institutions with which the senior personnel (PI, co-PIs, and any named personnel) have financial ties, including advisory committees (please specify type). (This list generally replicates information that should be provided in the biographical sketches, but it is collated into one alphabetized table to facilitate the identification of individuals who would have conflicts of interest in the review of the proposal.)" (Program Solicitation NSF 11-551).
The program solicitation to which you are applying will specify whether or not a Conflict of Interest Matrix is required. If it is required and you do not include it, or include a blank document, your proposal may be returned without review.
UAF employees should also be aware of the other conflicts of interest managed by their Human Resources Department:
Immediate Family Disclosure
"The Alaska Ethics Act (AS 39.52.010 through 960) prohibits all public employees, including University employees, from taking or withholding official action in order to affect a matter in which that employee has a personal or financial interest. Among other things, this prohibits an employee from taking or withholding action on employment contracts involving members of their immediate family. Effective January 1, 1999, “immediate family member” is defined by statute to include a spouse, child, including stepchild or adopted child, a parent, sibling, grandparent, aunt, or uncle of the employee, a parent or sibling of the employee’s spouse. It also includes “another person cohabiting with the [employee] in a conjugal relationship that is not a legal marriage." Employees who are involved in a situation that may be in violation of these statutory prohibitions are requested to complete this form."
Outside Activities Disclosure
Employees also must disclose any work they perform outside of their University employment. Examples of outside activities that must be disclosed are: self-employment, independent contracting, or consulting. In addition, any volunteer or uncompensated work performed outside of the University must be disclosed if there is any possibility that the work might involve the same issues or people as your University duties. If you have no outside activities, you are not required to submit a form. All employee and employee family member interests in contracts with the University must be disclosed and pre-approved using the Interest in Contracts form, not the Outside Employment form. Note that employment of your “Immediate Family Members” by the University is an interest in a contract with the University. It must be disclosed using the Nepotism or Interest in Contracts forms. In case of doubt, be on the safe side and disclose.