Procedures for Conflict of Interest in Grants and Contracts for Principal Investigators 

 

Responsibilities

It is the responsibility of the Principal Investigator of a grant or contract to identify all investigators (as defined above) – that is, all persons with design, conduct or reporting responsibilities on the grant or contract – whether or not they are identified in the proposal, grant or contract, and ensure that they follow the provisions of this policy.

It is the responsibility of each Investigator (as defined above) to disclose any changes or newly identified financial conflicts that arise during the course of the funded project.

The Division of Research and Graduate Studies shall provide a copy of this policy statement to Investigators at the time of application for a project to be submitted to a non-governmental agency and/or a federal agency requiring such reporting.

The Recipient (Foundation or University) will include information about Conflict of Interest disclosure in the PI handbook.

The Recipient will notify PIs of annual deadlines for multi-year awards and annual/final reporting.

The Recipient will notify subrecipients of the Conflict of Interest requirements.  Subrecipients of externally funded projects from nongovernmental and specified federal agencies will be asked to submit Conflict of Interest declarations or proof of an acceptable Conflict of Interest policy prior to receiving funding.  The recipient will ask the subrecipient to complete disclosure forms prior to full execution of any subcontract.

The Office of Human Resources at the university will review and store the originals of all disclosure forms.  Copies of such forms will be filed in the submission folder and grant folder if awarded. 

 

Managing Conflicts of Significant Financial Interest

Upon initial review of the disclosure form, the Office of Human Resources will determine if there is any potential conflict of interest covered by this policy, and if so, will submit it to the Conflict of Interest Review Committee.

The Committee shall be composed of:  the Associate Provost, the AVP for Financial Services, and the AVP for Academic Personnel. 

Each member of the Committee is to be familiar with the State and Federal regulations governing conflicts of interest. 

The Committee shall review all statements regarding potential conflicts of interest submitted by the Office of Human Resources. 

When the Committee believes a “significant” conflict of interest exists under either State or Federal regulations, it shall: 

          (1) inform the employee and Office of Human Resources;

          (2) with the appropriate Dean, draft a Resolution Plan that details steps that will be taken to manage, reduce, or eliminate the conflict of interest                  prior to acceptance of funding; and

         (3) enter into an MOU between the university and investigator that details the conditions or restrictions imposed upon the investigator in the                         conduct of the project or in the relationship with the business entity. 

Examples of conditions or restrictions that might be imposed to manage, reduce, or eliminate actual or potential conflicts of interest include, but are not limited to: 

          • public disclosure of significant financial interests;

          • monitoring of the project by independent reviewers;

          • modification of the project plan;

          • disqualification from participation in all or a portion of the project;

          • divestiture of significant financial interests; and/or

          • severance of relationships that create actual or potential conflicts.

Records of investigator financial disclosures and of actions taken to manage actual or potential conflicts of interest shall be retained by the Recipient (Foundation or University) until three (3) years after the date of termination or completion of the award to which the documents relate, or the resolution of any government action involving these records. 

Actions for Noncompliance 

Anyone found to be noncompliant with the University Independent Review Committee requests and/or in violation of this policy will be reported to the Provost for further action.  If sanctions are imposed, they may range from a formal reprimand to the imposition of disciplinary action as defined in Article 19 of the Memorandum of Understanding (MOU) between The California State University and the California Faculty Association.