Guidelines for PHS and NSF Conflict of Interest Policies
On July 11, 1995. both the National Science Foundation (NSF) and the Public Health Service (PHS) issued final policies that deal with conflicts of interest. The NSF policy is titled "Investigator Financial Disclosure Policy" and the PHS policy is titled "Objectivity in Research." Both were published in the Federal Register. The substance of both policies is similar.
In accordance with the NSF and PHS policies, institutions must maintain an appropriate written and enforced policy on conflict of interest that includes:
- Limited and targeted financial interests that would reasonably appear to be affected by the research or educational activities funded.
- Disclosure of any significant financial interests that would reasonably appear to be affected by the research or educational activities funded.
- Designation of person(s) to review the disclosures to (1) determine whether the disclosed interests could directly and significantly affect the design,
conduct, or reporting of the funded research; (2) Resolve actual or potential problems revealed.
- Update of disclosure during the award period, either annually or as new reportable significant financial interests are obtained.
- Guidelines to identify conflict of interest and provide for management, reduction, and elimination.
- Maintenance of records of all financial disclosures and actions taken.
- Enforcement mechanisms and sanctions where appropriate.
The Research Foundation Board of Directors approved the Foundation's "Conflict of Interest Policy" in Resolution 95-5. The Foundation's policy substantially complies with the NSF and PHS policies.
There are several key areas where operating locations need to implement additional procedures for proposals and projects NSF and PHS.
- PHS requires awardee institutions to take reasonable steps to assure subrecipient compliance with the PHS "Objectivity in Research" policy.
- Both PHS and NSF require submission of the disclosure at the time the proposal is submitted.
- Both PHS and NSF require that an institutional representative certify that any identified conflict of interest will be managed, reduced, or eliminated prior
to the institution's expenditure of funds under the award.
- Under PHS NSF rules, any conflict of interest that cannot be managed, reduced, or eliminated must be reported to the NSF Office of the General
- Under PHS PHS rules, the institution must report the existence of a conflict of interest and assure that the conflict has been managed, reduced, or
eliminated within 60 days of the identification.
- Because certain large on-going projects are incrementally funded without new proposals, NSF is requiring a certification at the first funding increment
occurring after 10/1/95 for all continuing grant increments exceeding one million dollars.
National Science Foundation's "Investigator Financial Disclosure Policy" was published in the Federal Register as a Notice of Changes on June 28, 1994 (59 FR 33308). A Notice of Technical Changes was published on July 11, 1995 (60 FR 35820).
Public Health Service's "Objectivity in Research" policy was published in the Federal Register as a Notice of Proposed Rulemaking on June 28, 1994 (59 FR 33242). The Final Rule was published on July 11, 1995 (60 FR 35809). A Correction was issued on July 31, 1995 (60 FR 39076).
NSF & PHS FAQ issued in 1996: a document that responds to frequently asked questions regarding the NSF and PHS issued rules on investigator conflicts of interest (61 FR 34839, July 3, 1966).
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