91¶ÌÊÓƵ

I. PURPOSE

To define policy regarding conflict of interest between an individual and 91¶ÌÊÓƵ in the course of performance of a sponsored project. This policy is in concert with 2 CFR 200 (Uniform Guidance) and 91¶ÌÊÓƵ Policy 3-36: Conflict of Interest for 91¶ÌÊÓƵ.

II. REFERENCES

• 2 CFR 200 (Uniform Guidance) 
• 91¶ÌÊÓƵ Policy 3-36
• 91¶ÌÊÓƵ Policy 5-13
• 91¶ÌÊÓƵ Policy 5-39

III. POLICY

A. For NSF and DHHS (NIH, NIMH, PHS), DOE, or any other government agency, grant applications, any university employee is required to disclose anything that could present or could be perceived as presenting a conflict of interest with respect to external awards prior to the submission of the grant application.

B. Significant financial interest is defined as anything of monetary value, including but not limited to: Salary or other payments for services (e.g., consulting fees or honoraria), equity interests (e.g., stocks, stock options or other ownership interests), intellectual property rights (e.g., patents, copyrights and royalties from such rights).

C. As required by the federal regulations, it is the responsibility of the individual to disclose all significant financial interests prior to the time a proposal is submitted, and any conflict of interest must be resolved prior to the expenditure of grant funds. All financial disclosures must be updated by the individual during the period of the award, either on an annual basis or earlier, as new reportable significant financial interests are obtained.

D. This policy also applies to situations in which the University (and/or its faculty or employees) are involved, either as subcontractors, in grants made to another institution. Collaborators from outside the University must either comply with this policy or provide a certification that their institutions are in compliance with federal policies regarding investigator significant financial interest disclosure and that their portion of the project is in compliance with their institutional policies.