Conflict of Interest Policy

In order to comply with Federal regulations, Ithaca College has a responsibility to manage, reduce, or eliminate any actual or potential conflicts of interest that may be presented by a financial interest of an Investigator. The College requires that Investigators disclose any Significant Financial Interest that would reasonably appear to be directly and significantly affected by an actual or potential conflict of interest in relationship with a sponsored project.  The Financial Conflict of Interest (FCOI) policy (see link below) applies to all awards administered by the Sponsored Research office at Ithaca College and to all Investigators who apply for, receive, plan to participate in or are participating in sponsored programs.

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.
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 

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)


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.

Disclosure Procedures for Researchers

The forms and disclosures aforementioned have been updated in accordance with 42 CFR 50, Subpart F, "Responsibility of Applicants for Promoting Objectivity in Research for which PHS Funding is Sought".

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.

FAQs on Responsibility of Applicants for Promoting Objectivity in Research

NIH Policy