Financial Conflicts of Interest Policy
Link to Policy
A potential conflict of interest occurs when there is a divergence between an individual's private interests and his or her professional obligations to Nova Southeastern University (NSU) such that an independent observer might reasonably question whether the professional actions or decisions of an individual is determined or influenced by considerations of personal gain, financial or otherwise. An actual conflict of interest depends on the situation and on the character or actions of the individual. For the purposes of NSU Office of Sponsored Programs Policy (OSP) #16, Financial Conflicts of Interest in Sponsored Programs, a conflict of interest exists when the University, through procedures described herein, reasonably determines that a significant financial interest could affect directly and significantly the design, conduct, or reporting of sponsored projects.
The increasing involvement of academic researchers and educators with industry and private entrepreneurial ventures has raised the potential for conflict of interest. Such real or apparent conflicts, when not appropriately disclosed and addressed, can undermine public and professional confidence in the integrity of University research and sponsored programs.
In accordance with Federal regulations, NSU has a responsibility to manage, reduce, or eliminate any actual or potential conflicts of interest that may be present in a Study Team. OSP Policy #16, Financial Conflicts of Interest in Sponsored Programs , is intended to meet the federal requirements governing disclosure, management and reporting of financial conflicts of interest (FCOI's). Complying with the policy ensures that potential conflicts are disclosed to the University and that the University manages, reduces, or eliminates FCOI's and reports them to the sponsors so there is a reasonable expectation that the research is unbiased and the public trust is preserved.
The Vice President for Research and Technology Transfer is the designated University official for for review of financial disclosures by Investigators and for determining whether any significant financial interest is related to the sponsored program and, if so, whether a financial conflict of interest exists.
The policy is applicable to Investigators/Study Team members on sponsored programs funded by, or proposed to, the Public Health Service (NIH, HRSA, CDC, AHRQ, SAMHSA, and others), the National Science Foundation, and any other governmental agency if they have promulgated regulations requiring investigator disclosure of financial interests or institutional policies related to conflicts of interest on sponsored projects.
Each Project Director/Principal Investigator (PD/PI) at NSU to whom OSP Policy #16 applies is responsible for identifying and disclosing his or her significant financial interests/obligations/proprietary interests and for ensuring that Study Team members (i.e., Investigators) identify and disclose their interests.
As defined in OSP Policy #16, a Study Team member (i.e., Investigator) is any person, including the project director or principal Investigator, who is responsible for the design, conduct or reporting of the program described in the proposal including sub-awardee(s), sub-contractor(s), consultants and "to be appointed" positions as well as any individual whose biographical sketch is included in the proposal or whose name appears in the budget (including subcontract budgets). A Study Team member's spouses, domestic partners, and dependent children are also included for purposes of disclosure and conflict of interest review. If a sub-awardee does not have its own policy that complies with University regulations, the organization must follow NSU policies regarding disclosure.
There are two forms that are to be used for the purposes of disclosure: the Financial Interests/ Obligations/ Proprietary Interests Disclosure (FID) and the Individual Interest Disclosure (IID), as applicable.
Financial Interests/Obligations/Proprietary Interests Disclosure (FID) Form Link to Form
All PD/PI's are required to complete a FID on behalf of themselves and the Study Team prior to application submission and at specific times during the period of award. Once completed, only the PD/PI is required to sign the FID. For proposals with multiple PD/PIs, only one FID is required but all PD/PIs must agree to the information contained in the FID and original signatures of all PD/PIs are required. For more information, review the Financial Conflicts of Interest in Sponsored Programs policy. Training is also available via the Collaborative Institutional Training Initiative (CITI) Conflict of Interest Course Module at http://www.citiprogram.org.
Individual Interest Disclosure (IID) Form Link to Form
If the FID identifies that a Study Team member has a significant financial interest, obligation, or proprietary interest, then an IID will need to be completed and submitted by the identified Study Team member.
Once disclosures are made, the University Official (Vice President for Research and Technology Transfer) will conduct a review to determine whether any disclosures are related to the proposed program, and if so, whether an actual conflict of interest exists.
What is FCOI training?
Office of Sponsored Programs Policy # 16, Financial Conflicts of Interest in Sponsored Programs, is intended to meet federal requirements governing disclosure, management, and reporting of financial conflicts of interest (FCOI’s). The policy requires that members of a study team to whom the policy applies (see Section II of the policy) participate in FCOI training prior to engaging in any sponsored program funded by the Public Health Service, the National Science Foundation, or any other governmental agency if the agency has promulgated regulations or policies requiring investigator financial disclosure or requiring institutional conflict of interest policies relating to the award of grants or contracts. Investigators must also complete training at least every four years thereafter, and immediately in certain designated circumstances as outlined in Policy #16.
How do I complete the training?
NSU is using the CITI Program's Conflict of Interest Mini-Course to meet the training requirement. To access the training, go to: http://www.citiprogram.org/.
If you do not have a CITI account, you must first create one by clicking “Register Here” from the CITI home page, selecting “Nova Southeastern University” as your participating institution, and completing the registration steps.
If you already have a CITI account:
- Login from the CITI Home Page with your username and password.
- Click on the clink “Add a course or update your learner groups for Nova Southeastern University”.
- Answer “Yes” or “No” to the question “Is this the first time doing the CITI Program as a member of the NSU Community?”
- If you answer “No”, you will be taken to the page where you can select the “Conflict of Interest” Course, which is located at the bottom of the page.
- If you answer “Yes” you will be asked to identify what area of research you are working in. Make sure to select “Conflicts of Interest” so this learner module will appear to you. Then you will be taken to the page where you can select the “Conflict of Interest” Course, located at the bottom of the page.
Federal regulations now require that information about significant financial interests and FCOI's of senior/key personnel on Public Health Service (PHS) funded research projects be made publicly accessible. The University will make such information available, upon written request, if the three requirements below are met:
- The significant financial interest was disclosed and is still held by the senior/key personnel (as defined in Policy)
- The University determines that the significant financial interest is related to the PHS-funded research
- The University determines that the significant financial interests is an FCOI.
To make a request for information, complete the form below and send it to firstname.lastname@example.org. A written response will be submitted in five days for requests meeting the above criteria.
Click here for " FCOI Information Request Form"