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Policies

Conflict of Interest for Funded Research Projects

Effective Date Jan 17, 2018
POC:
Senior Vice President for Research
Effective Date:
July 14, 2017
Approved by:
T. Dwayne McCay, President

The Disclosure of Significant Financial Interest, also referred to as the Financial Conflict of Interest (COI) policy, applies to all sponsored projects (e.g., research, educational and service) and to all employees of the university including student employees. The university will make reasonable efforts to ensure compliance with this policy by employees of sub-grantees and subcontractors. The provisions of this policy do not apply to the Program Phase I applications associated with the Small Business Innovation Research Program and the Small Business Technology Transfer Program.

The policy describes the Public Health Service (PHS) regulations concerning research and COI compliance requirements for faculty participating in National Institutes of Health (NIH) funded projects.

Principal Investigators (PIs) are to complete a “Statement of Significant Financial Disclosure” in the following instances:

  • As part of a proposal package with each proposal to be submitted for a sponsored project
  • Annually through the PAWS systems if serving as PI on any active funded project.

Florida Institute of Technology acts in accordance with federal regulations set forth within OMB Uniform Guidance governed by 2 CFR 200 Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards as well as the Federal Office of Management and Budget (OMB) Circular A-21. Compliance with these principles is necessary to ensure continued federal funding for sponsored programs and activities.

Statements of Significant Financial Interest (SFI) records are to be retained for a three (3) year period from completion of the research pertaining to the project with the conflict or the end of the license agreement that is the subject of the conflict.

For guidance and further information, please review “Guidelines for Disclosure of Significant Financial Interest (SFI).”

This policy is based on the NIH Conflict of Interest policy and applied (except where noted) to all sponsored projects and all university employees inclusive of students.