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 Investigators may have. 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 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 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 Investigator at NSU to whom OSP Policy #16 applies is responsible for identifying and disclosing his or her significant financial interests/obligations/proprietary interests.
As defined in OSP Policy #16, an Investigator is the project director or principal Investigator and any other person, regardless of title or position, who is responsible for the design, conduct, reporting, on a sponsored award, which may include, for example, collaborators or consultants. Spouses, domestic partners, and dependent children are also included for the purposes of disclosure. If a sub-awardee does not have its own policy that complies with University regulations, the organization must follow NSU policies regarding disclosure.
Starting July 2023, NSU implemented Cayuse Outside Interests for managing required disclosures of significant financial and other interests. By using Cayuse Outside Interests in conjunction with the other Cayuse modules, investigators will be able to ensure that their disclosures are complete, up-to-date, and timely, in compliance with the requirements of research sponsors and NSU policy.
Cayuse Outside Interests is different form our prior method, but not in substantive requirements. The disclosure requirements under the FCOI policy and research sponsor terms have not changed. With the Cayuse Outside Interests module, investigators will be asked specific, policy-driven questions to determine whether they have any of the types of financial or foreign interests that require disclosure, and will be able to easily update and track those disclosures electronically in one system. The status of a investigator’s disclosure compliance will be integrated with the Cayuse proposal and award systems, but the details of financial disclosures will remain confidential and access will remain limited to the offices at each campus tasked with managing the FCOI process.
With this transition, DoR will now have an Annual Disclosure Campaign. Starting July 1, 2023, investigators will be required to complete one financial interest disclosure update in Cayuse each year, and PI’s will no longer have to complete separate updates for each project.
Investigators will still be required to submit research-based disclosures for each new proposal submission, as required per federal regulations.
You can access the Cayuse Outside Interest site at: https://nova.app.cayuse.com/
Please reference the step-by-step user guide we have created to assist you in accessing and completing your financial disclosures.
If you experience any technical issues, please email firstname.lastname@example.org with a detailed explanation of the error and provide screen shots whenever possible.
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 Investigators 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 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:
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:
To make a request for information, complete the form below and send it to email@example.com. A written response will be submitted in five days for requests meeting the above criteria.
Click here for " FCOI Information Request Form"