Conflict of Interest

Forms Required for Researchers:

Section 1 - Significant Financial Interest Disclosure - Ithaca College requires all federally funded Investigators to submit Section 1 annually.

Section 2 - Complete only if answered "yes" or "not certain" in Section 1.

Public Health Service (PHS) Funded Travel Disclosure - see below.

Changes and Disclosure Procedures for Researchers (Fall 2012)

Effective August 24, 2012, UPPS 02.02.07, Researcher Conflicts of Interest in Research and Sponsored Program Activities, has been updated in accordance with the Public Health Service Regulation at 42 C.F.R. Part 50, Subpart F. In addition, changes have been made to the submission procedures for Financial Interest Disclosures.

Disclosure Responsibilities - Each federally funded investigator will annually report according to the following schedule:

  1. at the time of internal routing application for sponsored funding;
  2. at least annually thereafter during the period of research activity; and
  3. at any time during the research within 30 days of the discovery or acquisition of a new reportable financial interest.

Key points for federally funded faculty researchers:

  • Researchers are now asked to disclose any Significant Financial Interests (SFI) rather than Financial Conflicts of Interest related to a current sponsor.

  • Ithaca College requires Annual SFI Disclosures from all federally funded researchers. All Ithaca College federally funded researchers must submit (at a minimum) an annual SFI Disclosure using the new online form. If researchers submitting a proposal have not yet filed an SFI Disclosure, they will be required to do so before proposal submission.

Key points for PHS-supported researchers:

  • PHS-supported researchers must complete online COI training through CITI prior to account set up.

  • In addition, PHS-funded investigators must disclose within 30 days of travel, the occurrence of any travel expenses reimbursed directly to them (not through Ithaca College) or paid directly on their behalf, related to their institutional responsibilities. This disclosure does not apply to travel that is reimbursed or paid by a federal, state, or local government agency, an institution of higher education, an academic teaching hospital, a medical center, or a research institute that is affiliated with an institution of higher education.

If you are NOT responsible for the design, conduct, or reporting of research funded by the Public Health Service (PHS) you are not required to disclose travel expenses.

If you ARE responsible for the design, conduct, or reporting of research funded by the Public Health Service you must disclose third-party paid travel related to your institutional responsibilities that exceeds $5,000 per year from a single entity. (See sidebar for details.)

FAQs for 2011 Regulations

NIH Policy

What Do I Have to Do?

All federally funded researchers:

  1. Complete Section I of the Disclosure Forms

PHS-funded researchers must also:

  1. Complete CITI Training - Conflict of Interest
  2. Complete Section I of the Disclosure Forms
  3. Complete Section II of the Disclosure Forms if you answered "Yes" to any questions on Section I.
  4. Also complete the Travel Disclosure Form if you need to complete Section II.

You will receive a copy of the completed form in a confirmation email after submission.

What is a PHS-funded Agency?
  • Health Resources and Services Administration (HRSA)
  • National Institutes of Health (NIH)
  • Substance Abuse & Mental Health Services Administration (SAMHSA)
Travel

Third-party paid travel means:

  • Third party directly pays in whole or in part for travel on your behalf.

  • You pay for travel and the third party reimburses you in whole or in part.

  • Ithaca College pays in whole or in part for travel and the third party reimburses Ithaca College.

PHS regulations require you to disclose travel paid by:

  • External professional organizations and societies;

  • Academic journals and publishing companies; and

  • ANY travel reimbursed or sponsored by a foreign Institution of higher education or the government of another country.

PHS regulations exclude travel paid by:

  • Ithaca College or funded by a sponsored award to Ithaca College;

  • U.S. federal, state, or local government agencies;

  • U.S. institutions of higher education or U.S. research institutes; and

  • U.S. academic teaching hospitals or U.S. medical centers that are affiliated with U.S. institutions of higher education.