Sponsored Project Conflicts of Interest
If you work on a project funded by a sponsor that requires disclosure of a financial conflict of interest (FCOI), you are required to disclose certain activities and funding per SIUE’s Policy on Conflicts of Interest and Commitment 1Q9. The below procedures may be modified by the Graduate School as necessary to remain compliant with appropriate rules and regulations with notification of changes sent to the Graduate Council and other appropriate governing bodies.
Disclosure and Training Procedures
No activity on the sponsored project can be conducted until the SIUE Financial Conflict of Interest Disclosure has been approved.
1. An Investigator is responsible for submitting a completed online SIUE Financial Conflict of Interest Disclosure to disclose his or her significant financial interests (SFIs) as well as those of the Investigator’s spouse and dependent children that are related to the Investigator’s institutional responsibilities and that meet or exceed the regulatory definition of SFI.
2. Investigators must submit the SIUE FCOI Disclosure(s) no later than at the time of application for projects funded by any sponsor that requires disclosure of FCOI, which includes all federal agencies. Disclosure(s) are required prior to beginning work on funded projects.
3. The lead investigator is responsible for assuring all investigators as defined in Policy 1Q9 have filed appropriate disclosures with the Graduate School.
4. Complete the disclosure. Log in with your e-ID and password and navigate to the COI module. Click "Create or Update Annual Disclosure." Kuali Research assistance is also available.
*Note, annual reports or pre-approval of outside employment will be completed in Kuali Build. That information will need to be re-entered in the Kuali Research disclosure form for review relevant to the research and sponsored project activity.
5. Disclosure(s) must be updated:
- at least annually during the period of an award
- within 30 days of discovering or acquiring a new SFI. (An SFI includes any reimbursed or sponsored investigator travel related to his or her institutional responsibilities. Reimbursed or sponsored travel includes travel which is paid on behalf of the investigator but not reimbursed directly to the investigator.)
6. Each Investigator is required to complete appropriate training, such as through the CITI Program FCOI online course, prior to engaging in activities related to any grant from a sponsor requiring FCOI disclosure. This training is required every three years or if substantial policy or regulatory changes result in changes to the training or if an Investigator is out of compliance with the policy or a management plan.
Foreign Influence
SIUE is committed to building partnerships and international collaboration to continue the openness of the US research enterprise while working to prevent improper foreign government influence on federally funded research.
The Federal Government has released guidance to ensure full transparency in federal funding applications and throughout the life of a grant through the disclosure of all sources of research support, foreign components, and financial conflicts of interests.
1. Foreign Government Talent Programs.
On June 7, 2019, the Department of Energy (DOE) issued an order of new requirements for participation in foreign government talent recruitment programs. For more information on what is included in the new requirements, check out the Department of Energy’s Order.
Effective May 20, 2024, the National Science Foundation (NSF) requires all individuals identified as senior/key persons certify at proposal submission and annually afterwards for the duration of the award that they are not a party to a Malign Foreign Talent Recruitment Program (MFTRP) per PAPPG Chapter II.D.1.e(ii). This new certification is included on both the biographical sketch and current and pending (other) support forms in SciENcv.
2. Current and Pending Support.
The NSF released Proposal and Award Policies and Procedures Guide (PAPPG (NSF 24-1)) that includes clarifications regarding reporting requirements for both current and pending support and professional appointments. All current and pending support disclosure is required, foreign or domestic. To better help with consistency, the NSF released Frequently Asked Questions (FAQs) Regarding Current and Pending Support and a helpful disclosure chart to help clarify what information is required on proposal submission documents.
Different agencies have different required formats for disclosure of current and pending support. All current and pending support that is disclosed at the time of grant proposal should match what is disclosed as a Conflict of Interest, Commitment, or FCOI. The NIH released examples of what should be disclosed on applications for awards.
SIUE has modified our Kuali Conflict of Interest disclosure form to include questions on participation in foreign government talent recruitment program and funding from foreign entities. Full disclosure of all support and/or appointments is vital to the integrity of research and failure to disclose may be considered research misconduct. For more information, see SIUE's Research Integrity webpage.
3. NIH Other Support
On March 12th, 2021 the NIH released a notice of upcoming changes to the Biographical Sketch and Other Support forms. The notice included the following changes:
- New formats to the biographical sketch and other support forms.
- Required attachment of supporting documents to “Other Ssupport” if any investigators/key personnel are receiving foreign support.
You can find more information about the changes in our OPR News announcement or the NIH’s website. The forms will be required for all NIH grant applications beginning January 25th, 2022. Changes to the proposal certification questions to capture the changes will take effect before May 25th, 2021.
