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UMBC Procedures for Reporting Individual Financial Conflicts of Interest in NSF Research

Proposals submitted via FastLane require the Office of Sponsored Programs to “agree” with NSF’s guidance on conflict of interest certification when the proposal is electronically signed. This certification states that UMBC has implemented and is enforcing a written policy on conflicts of interest (COI). This certification states UMBC, the best of its knowledge, is following conflict of interest policies and “…that conflicts of interest, if any, were, or prior to the organization’s expenditure of any funds under the award, will be, satisfactorily managed, reduced or eliminated in accordance with the organization’s conflict of interest policy.”

Investigators, who have the responsibility for the design, conduct or reporting of NSF research, are required to disclose any situation that could conceivably be viewed as a conflict of interest or a reportable financial interest using the procedures found in UMBC’s Policy on Individual Conflicts of Interest in Research & Product Development. Such disclosures should be made at the earliest possible time to afford the best protection of an investigator’s interests. When in doubt, it is safer to disclose.

Disclosure Process

At the time a proposal is submitted, any individual who is considered an “Investigator” in a NSF award is required to complete and sign a COI Financial Disclosure Form for each proposal. This form must be submitted to the Office of Research Protections and Compliance at the time a proposal is submitted to the Office of Sponsored Programs. Investigators must complete the Office of Sponsored Programs’ “Addendum to Routing Form for NSF and NIH/PHS Proposals” at the time of proposal submission to OSP to document the assessment of COI.

Note: there is no requirement for disclosing travel or mandatory conflict of interest training for NSF COI disclosures.

Review Process

Upon submission, the ORPC will screen the disclosure information in the COI Financial Disclosure Form for applicability and completeness. As necessary, the form is then submitted to the Assistant Vice President for Research (AVPR) for review to determine if any action is required and if necessary, create a COI Management Plan to manage, reduce or eliminate the Conflict of Interest. This review may also require a meeting of a Conflict of Interest Committee to decide certain activities may be prohibited when potential Conflicts of Interest are too difficult to manage, reduce, or eliminate.

Once the AVPR has developed an appropriate COI Management Plan, a copy will be provided to the individual and his/her department chair or supervisor for review and comment. Once finalized, COI Management Plans are submitted to University Counsel for review and to the UMBC President for the final decision to accept or reject a COI Management Plan.

Conflicts which cannot be satisfactorily managed, reduced or eliminated must be disclosed to NSF.

Continuing obligations concerning conflict of interest

Investigators are responsible for updating disclosure forms annually during the period of the research, and within 30 days of identifying, changing or acquiring a new financial interest. ORPC will send notification prior to the anniversary of the initial COI disclosure to update any information.

Forms

COI Financial Disclosure Form – 06/13/2014

last updated: 06/23/2014