Sponsor-Specific Requirements
Contact COI if any additional requirements may apply to your proposal or award.
Some sponsors extend Conflict of Interest requirements beyond those of the Public Health Service (PHS) regulations and the University Individual Financial Conflict of Interest in Research Policy. These may apply at the proposal and award phases.
Consult Types of COI and the Transition page to learn more about Conflict of Interest processes.
Sponsor-Specific Requirement Chart: Summary
Please review each of these tabs carefully for the relevant information from your agency, before proposal.
Contact the Conflict of Interest (COI) Office if any condition may apply to you. If none apply to you, then no action is needed.
Some sponsors have additional Conflict of Interests requirements. Contact the Conflict of Interest (COI) Office immediately if one may relate to an upcoming research proposal or award.| Agency | Specific Requirements & Focus | Unique Standards/Nuances | Action Items (Contact COI Office if…) |
|---|---|---|---|
| DOJ | Must identify personal, financial, or organizational conflicts affecting research integrity. | Distinguishes between “Conflict in Fact” and “Conflict in Appearance”. | You are in a position to evaluate a spouse or colleague’s work, or are involved in decisions regarding family, partners, or organizations where you serve as an officer. |
| NPS | Requires safeguards for real or apparent conflicts with outside interests. | Includes a “reasonable person” impartiality test and mentions future employment arrangements. | Any personal relationship, financial interest, or position of trust in an outside organization creates a conflict with your project responsibilities. |
| EPA | Standards are broader than NIH and standard university disclosure systems. | Uses an expanded “immediate family” definition; screens for unfair competitive advantage. | An immediate family member (including in-laws, step-relations, or grandparents) has a relevant interest , or if an EPA employee assisted with your proposal. |
| DOE | Requires a specific disclosure certification as a condition of funding. | Certifies truthfulness under penalty of criminal or civil law for omissions. | You have a relationship that meets DOE requirements or if your circumstances change during the period of performance. |
| NSF | Transparency regarding private business ownership and associated financing. | Total ownership and investment interests must be accounted for at 100%. | You hold equity in a private business; you must identify all other investors by name to reach the 100% ownership mark. |
Department of Justice (DOJ)
The Department of Justice policy prohibits any undisclosed personal conflict, including situations where an investigator may evaluate a spouse’s work product, or the work of a former/current colleague.
If your answer to any of these questions is yes, please contact the COI Office.
- Do you have a personal or work relationship where there is involvement in this project which would meet the examples provided in the DOJ’s Grant Application Guide?
- Do you have any personal or professional relationship, inside or outside the University, which would meet the Conflict in Fact criteria from the Grant Financial Assistance Guide?
- Do you have any personal or professional relationship, inside or outside the University, which would meet the Conflict in Appearance criteria from the Grant Financial Assistance Guide?
- If you are the Lead PI, you must understand that DOJ and any affiliate entity requires an Organizational COI review?
If you have any relationship or interest that may meet this standard, or if new circumstances arise during the project, you must report it to the Conflict of Interest (COI) Office promptly.
Grant Application Resource Guide:
Assurance of No Conflict: A specific description of actual or potential apparent conflicts of interest that the applicant has identified — including through review of pertinent information on the principal investigator, any co-principal investigators, and any subrecipients — that could affect the independence or integrity of the research, including the design, conduct, or reporting of the research. These conflicts may be personal (e.g., on the part of investigators or other staff), financial, or organizational (related to the applicant or any subrecipient entity). Some examples of potential investigator (or other personal) conflict situations are those in which an investigator would be in a position to evaluate a spouse’s work product (actual conflict), or an investigator would be in a position to evaluate the work of a former or current colleague (potential apparent conflict).
National Park Service (NPS)
The National Park Service standards have a broader scope of outside interests, as defined below. The University must notify the NPS Awarding Officer promptly of any actual or potential conflicts that arise during the life of the award.
If you have any relationship or interest that may meet this standard, or if new circumstances arise during the project, you must report it to the Conflict of Interest (COI) Office promptly.
Highlighted Section from NPS Guidance
The [University] must establish safeguards to prohibit its employees and Subrecipients from using their positions for purposes that constitute or present the appearance of a personal or organizational conflict of interest. The [University] is responsible for notifying the Awarding Officer [at the National Park Service] in writing of any actual or potential conflicts of interest that may arise during the life of this award.
Conflicts of interest include any relationship or matter which might place the [University] or its employees in a position of conflict, real or apparent, between their responsibilities under the agreement and any other outside interests. Conflicts of interest may also include, but are not limited to, direct or indirect financial interests, close personal relationships, positions of trust in outside organizations, consideration of future employment arrangements with a different organization, or decision-making affecting the award that would cause a reasonable person with knowledge of the relevant facts to question the impartiality of the [University] and/or the [University’s] employees and Subrecipients in the matter.
Acknowledgement: I have read the NPS standard for conflict of interest and have reported any applicable relationships, interests or information, as defined by the NPS, in this disclosure. I understand my ongoing obligation to report any new relationships, interests or other changes which might trigger a conflict of interest review based on the NPS standard.
Environmental Protection Agency (EPA)
The Environmental Protection Agency (EPA) applies conflict of interest (COI) with a broader definition of immediate family than PHS regulations, as defined below. The University expects you to abide by EPA policies when submitting relevant proposals.
If you have any relationship or interest that may meet this standard, or if new circumstances arise during the project, you must report it to the Conflict of Interest (COI) Office promptly.
In particular, EPA uses a broader definition of “immediate family” that extends beyond spouse/partner and dependent children to include:
- parents
- siblings,
- in-laws,
- grandparents,
- grandchildren,
- step-relations, and
- spouses of grandparents or grandchildren.
Highlighted Section from EPA Guidance
The EPA has instituted a COI policy for its agency which is broader than the NIH regulations, which is the basis for our current on-line system. For example, the University uses the definition of you, spouse/partner and dependent children for “immediate family”. The EPA’s definition is much broader. For your reference, the EPA’s Financial Assistance Conflict of Interest Policy is available at https://www.epa.gov/grants/epas-financial-assistance-conflict-interest-policy
When answering the COI questions related to this project, including additional entities that might be involved, please answer using the EPA definition for immediate family:
For the purposes of this EPA COI Policy only, unless otherwise defined in a state, tribal or local government recipient or subrecipient’s laws, ordinances, or other legally binding enactments, Immediate Family includes a person’s husband or wife; natural or adoptive parent; child or sibling; stepparent, stepchild, stepbrother or stepsister; father-, mother-, daughter-, son-, brother- or sister-in-law; grandparent or grandchild; or spouse of a grandparent or grandchild.
Acknowledgement:
I understand I need to answer the conflict of interest questions using the EPA definition of immediately family, not just spouse/partner and dependent children. I will put any information, other than spouse/partner, under the selection of “dependent children” and explain in the additional information box at the end of the disclosure.
Department of Energy (DOE)
The Department of Energy (DOE) requires all awardees to certify their COI during proposal.
If you have any relationship or interest that may meet this standard, or if new circumstances arise during the project, you must report it to the Conflict of Interest (COI) Office promptly.
The University expects you to abide by DOE policies when submitting relevant proposals.
I understand that this Disclosure is required to obtain funding from the U.S. Government. I, [NAME AND TITLE], certify to the best of my knowledge and belief that the information contained in this Disclosure Statement is true, complete, and accurate. I understand that any false, fictitious, or fraudulent information, misrepresentations, half-truths, or omissions of any material fact may subject me to criminal, civil, or administrative penalties under applicable federal law (18 U.S.C. §§ 1001 and 287; 31 U.S.C. §§ 3729–3730 and 3801–3812). I further understand and agree that (1) the statements and representations made herein are material to the U.S. Government’s funding decision, and (2) I have a responsibility to update this disclosure during the period of performance of the award should circumstances change.
National Science Foundation (NSF)
The National Science Foundation (NSF) requires investigators who disclose equity in a private business to also disclose any venture or other capital financing associated with that business. A full account of business ownership and investment is required.
If you have equity, and submit a proposal to National Science Foundation (NSF), then please contact the Conflict of Interest Office to provide information about all investors in your business—by individual or entity/group name—to the best of your knowledge. The combined ownership or investment interests must total 100%.
If you have any relationship or interest that may meet this standard, or if new circumstances arise during the project, you must report it to the Conflict of Interest (COI) Office promptly.
Effective 1/30/2023, NSF is now requiring investigators who disclose equity in a private business to additionally disclose “venture or other capital financing” in this business. https://beta.nsf.gov/policies/pappg/23-1/ch-9-recipient-standards#a-conflict-of-interest-policies-28e
Please enter any other investors in this business in the table below, either by individual or entity/group name, to the best of your knowledge. The total amount all investors will need to add up to 100%. As a reminder, in accordance with the University’s COI Policy, the COI Disclosure forms are considered to be confidential; however, such information may be shared with those in the University who have a business need to know or in accordance with applicable law.