Conflict of Interest
Conflicts of Interest (COI) typically involve circumstances that impair, or reasonably appear to impair, an individual's independent unbiased judgment in the discharge of his/her responsibilities to the Univeristy. One of the important themes in addressing COI is transparency, and the first step is the disclosure of your interests, as required below.
University Conflict of Interest Policy - Instructions for All Clarkson Investigators
Faculty and Staff of Instruction and Research must complete a Conflict of Interest Disclosure Form at the beginning of each fiscal year in order to meet Federal requirements. The Director of Research and/or the Conflict of Interest Committee reviews each disclosure.
Faculty and Staff of Instruction and Research are reminded that Conflict of Interest Disclosure Forms need to be updated not only annually, but also when a new reportable significant financial interest is first identified.
For additional information on Clarkson University's Conflict of Interest Policy, the Conflict of Interest Disclosure Form, or a COI tutorial, see the links below.
Policy, Form, and Tutorial
Conflict of Interest Policy
Conflict of Interest Disclosure Form
COI Self-Guided Review
NEW PHS COI Policy - Instructions for all NIH Investigators and Other PHS Investigators Only
New conflict of interest regulations go into effect for all institutions submitting proposals to and receiving funding from any U. S. Public Health Service (PHS) agency, such as the National Institutes of Health (NIH), August 24th, 2012.
What do I need to do as a Clarkson Researcher?
1. Prior to submitting a proposal to NIH (or other PHS agency) on or after August 24, 2012 you:
- Must submit a PHS COI Disclosure Form to the DoR or if one is on file already, verify it is up-to date;
- Should complete the CITI Program web-based PHS COI training (required every four years); and
- Should attend one of the scheduled information sessions or meet independently with the DoR (one time only).
2. Prior to engaging in NIH (or other PHS agency) research with a notice of award date or noncompeting continuation beginning on or after August 24, 2012 you must:
- Have completed the CITI Program PHS COI training (required every four years);
- Have attended one of the scheduled information sessions or met independently with the DoR (one time only);
- Verify an up-to-date PHS COI Disclosure Form is on file with the DoR or complete a PHS COI Disclosure Form, if one has been previously submitted;
- If required, complete a COI Management Plan for all identified Financial Conflicts of Interest.
3. You must update your PHS COI Disclosure Form within 30 days of discovering or acquiring a new Significant Financial Interest.
4. You must disclose all reimbursed for travel or travel paid on your behalf by an entity that engages in activities that could reasonably be perceived by non-experts as being related to your Institutional Responsibilities with 30 days of the end of the trip by updating your PHS COI Disclosure Form.
5. You must submit an updated PHS COI Disclosure Form on an annual basis, when requested.
6. You must require anyone working on the PHS funded award that meets the definition of an “Investigator” to complete a PHS COI Disclosure Form, training, and comply with Clarkson’s Conflict of Interest Policy and Procedures for PHS Funded Research.
Policy, Procedure, Forms, and Training
Clarkson PHS COI Policy Memorandum
Clarkson's Conflict of Interest Policy and Procedures for PHS-Funded Research
PHS COI Disclosure Form
CITI Program PHS COI Training Instructions
PHS Revised FCOI Regulation
PHS Web-based Tutorial
Per 42 C.F.R. Part 50, Subpart F, any institution receiving PHS-funded research projects shall ensure public accessibility of information concerning any significant financial interest (SFI) disclosed to the institution provided that (a) the SFI is held by the senior or key personnel on the research project; (b) the institution has determined that the SFI is related to the PHS-funded research; and, (c) the institution has determined the SFI to be a financial conflict of interest (FCOI).
Public accessibility requests must be in writing and include the name of the senior or key personnel and the title of the PHS-funded research project. Requests will be answered in the manner they were received within five business days of receipt by the Designated Official in the Division of Research and shall include the information required to be disclosed per 42 C.F.R. Part 50, Subpart F. Access to annual updates or new SFIs that are determined to be FCOIs by the institution require a new public accessibility request.
Requests for public accessibility may be sent to the following individuals:
Director of Research and Technology Transfer
Research Compliance Officer