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I.  POLICY STATEMENT. 

17�Թ� (the “College”) encourages collaborations between academic institutions and private entities. To ensure that the design, conduct, or reporting of research is not compromised by an Investigator’s personal financial interests and commitments, the College maintains this policy in compliance with federal mandates from the Uniform Guidance (2 CFR 200), Public Health Service (PHS), the National Science Foundation (NSF), and other federal regulations. 

The purpose of this policy is to identify, evaluate, and manage real or potential conflicts of interest and preserve the integrity and objectivity of the College’s research enterprise. 

II. APPLICABILITY. 

This policy applies to all Investigators (including faculty, staff, and students) responsible for the design or conduct of any research project (whether sponsored or unsponsored), or reporting of a project submitted to or funded by either (1) PHS, which includes the National Institutes of Health (NIH), and any other sponsor that has adopted the PHS requirements, e.g. the Department of Energy (DOE) or (2) other federal (non-PHS) sponsored research, including NSF, National Aeronautics and Space Administration (NASA), and the U.S. Department of Agriculture (USDA).

• PHS Requirements: Applies to all research funded by PHS (including NIH), DOE, and any other sponsor that has adopted PHS financial disclosure requirements.
• Other Federal (Non-PHS) Requirements: Applies to all research funded by NSF, NASA, USDA, non-federal entities, corporate sponsors, or any other sponsor governed by Uniform Guidance.

III. DEFINITIONS. 

Financial Conflict of Interest (FCOI) - A financial interest that could directly and significantly affect the design, conduct, or reporting of research.

Investigator - The Principal Investigator (PI) or Project Director (PD), Co-Investigators, and any other person responsible for the design, conduct, or reporting of research.  This includes individuals working on IRB protocols tied to sponsored or unsponsored research projects.

Related Financial Interest (“RFI”) - Applies to federal (non-PHS) sponsors and requirements. A related financial interest is any financial or professional interest of (1) the Investigator (or the Investigator’s spouse and dependent children) or of (2) an entity (a) in which the Investigator has a financial interest (“Related Entity”) and (b) that would reasonably appear to be affected by the work to be performed under the sponsored project and/or its results (“Sponsored Work”). Financial interests that are considered “related" to a Sponsored Work include, but are not limited to, the following examples:

• Management Position: Holding a position as a founder, partner, director, manager, officer, trustee, scientific advisory board member, or employee with an outside entity (paid or unpaid) within the past 12 months.
• Commercialization and Product Development: The Related Entity might be able to develop, manufacture, improve, or commercialize a drug, device, procedure, service, or any other product used or that will predictably result from the Sponsored Work.
• Consulting and Professional Fees: The Investigator receives - from a single entity-   professional consulting income that exceeds $5,000 in twelve months, and such income could reasonably appear to affect the conduct or administration of the Sponsored Work.
• Contractual and Business Relationships: Any time that (1) all or a portion of the Sponsored Work will be subcontracted to, (2) property, space or equipment will be leased to, (3) participants will be referred to, or purchases will be made from the Related Entity.
• Participants and Consortia: The Related Entity is part of a consortium or will otherwise participate in the Sponsored Work.
• IP and Royalties: The Investigator, or their immediate family, holds the rights to intellectual property (patents or copyrights) that is used in the Sponsored Work and either (1) generates royalties for the Investigator or their immediate family, or (2) utilizes College facilities, property, or equipment to further the value of such intellectual property.

Significant Financial Interest (“SFI”) - Applies to PHS sponsors and requirements, and must be disclosed. A financial interest consisting of one or more of the following interests of the Investigator (and those of the Investigator’s spouse and dependent children) that reasonably appears to be related to the Investigator’s institutional responsibilities:

• Publicly Traded Entities: Remuneration (salary, consulting fees, honoraria) received in the twelve months preceding disclosure plus the value of any equity interest as of the date of disclosure that, when aggregated, exceeds $5,000. 
• Privately Held Entities: Remuneration received in the twelve months preceding disclosure that, when aggregated, exceeds $5,000, or any equity interest (e.g., stock, options) regardless of dollar value. 
• Intellectual Property: Income related to such rights and interests (e.g., patents, copyrights), excluding interests assigned to the College. 
• Reimbursed or Sponsored Travel: (Specifically for PHS-funded Investigators) All travel related to institutional responsibilities, unless sponsored by a federal/state/local government or a U.S. institution of higher education.

Supervisor - The direct Supervisor of the Investigator( i.e. Department Chair or Dean), or another qualified designee of the Supervisor.

IV. POLICY.

A.        When to Disclose

Any Investigator must disclose at the following intervals:

1. Initial: At or before the time of proposal submission, including renewal proposals, continuations, and supplemental funding.
2. Annually: Every 12 months throughout the period of the award.
3. Ad Hoc: 
   1. PHS Requirements: Within 30 days of discovering or acquiring a new Significant Financial Interest. 
   2. Non-PHS Requirements: Within 30 days of a change in financial interest(s) or outside professional appointments.
4. New Personnel: As new Investigators are added to an ongoing project.

B. The Process

Financial Conflict of Interest Disclosure Form: All Investigators must submit a signed at or before the time of proposal submission, in addition to the disclosure intervals outlined above. For any SFI or RFI, the Investigator must describe the financial interest, outlining the nature and dollar value of the interest.

C. Review and Management Process

The Sponsored Research Office (SRO) is responsible for reviewing all disclosures to determine: 

• PHS Requirements: (1) if a disclosed SFI is related to the Investigator’s institutional responsibilities, and (2) if the SFI constitutes a Financial Conflict of Interest.
• Non-PHS Requirements: (1) if a disclosed RFI is related to the Sponsored Work, and (2) if the RFI constitutes a Financial Conflict of Interest.

If SRO determines that the disclosure requires further review or management, the disclosure will be submitted to the Supervisor for review and determination.

1. Determination  

A conflict of interest exists if the Supervisor reasonably determines that the financial interest or outside position  could directly and significantly affect the design, conduct, reporting, or administration of the Sponsored Work. The Supervisor will determine whether:

• Disapproval: A conflict of interest exists, and the department cannot recommend approval of this activity.
• No Management Required: A conflict of interest exists, but it is minimal and the department does NOT recommend management, reduction, or oversight.
• Managed: A conflict of interest exists, but it can be reduced, eliminated, or managed through a Conflict Management Plan.

2. Management, Reduction, or Elimination of Conflicts of Interest 

If a conflict is identified, the Supervisor will work with the Investigator to develop a Conflict Management Plan, which requires the Dean’s review and approval. Remedial measures may include:

• Public disclosure of the interest (e.g., in publications or presentations).
• Independent monitoring of the project.
• Modification of the project plan or personnel duties.
• Divestiture of the financial interest or severance of the relationship.

D. Compliance and Sanctions

• Award Acceptance: No funds may be expended until the disclosure review is complete and the management plan (if required) is signed.
• Reporting: The College will report Financial Conflicts of Interest to sponsors as required by the specific terms of the grant or applicable federal regulations.
• Records: The College maintains records of all disclosure and actions for a minimum of three years after the project’s completion.
• Non-Compliance: Failure to comply with this policy may result in the suspension of the award, debarment from future funding, or disciplinary action by the College, up to and including termination.

V. POLICY HISTORY.

Responsible Officer(s): Director of Sponsored Research

Effective Date: July 1, 2026

Last Revised Date: July 1, 2026

VI. RELATED POLICIES AND RESOURCES.

Intellectual Property Policy