Research and Sponsored Programs - 2018

Conflict of Interest

Conflict of Interest

The Research and Sponsored Programs (RSP) office is responsible for ensuring that the university adheres to sponsor and university policies and regulations regarding Conflict of Interest (COI) and Financial Conflict of Interest (FCOI) in connection with grants and contracts. A program’s source of funding will determine which conflict of interest requirements apply to a particular grant or contract.

Conflicts of Interest (COI)

In accordance with state and federal conflict of interest (COI) regulations, California State University, Northridge (CSUN) instituted a COI policy “to manage, reduce, or eliminate any actual or potential conflicts of interest involving activities conducted under the authority of the University or its auxiliary organizations.” This policy requires investigators supported by external funds to disclose significant financial interests that may constitute conflicts of interest.

As part of the proposal development process in Cayuse SP, the Principal Investigator is responsible for disclosing COI status on behalf of all investigators on that proposal's team.

In the event an investigator discloses a significant financial interest, the Associate Vice President, Research and Graduate Studies, or their designee, will determine whether a conflict of interest exists and will work with the investigator to develop a plan to resolve the conflict of interest.

  • Required for all externally-sponsored programs regardless of funding source
  • Required of all principal investigators, co-principal investigators, and project directors involved in the project
  • Submitted at the time of proposal submission and whenever new financial interests are obtained during the life of the award

Investigators are asked to disclose COI when creating a proposal record in Cayuse SP.

Financial Conflict of Interest (FCOI) Disclosure

CSUN has developed a policy to ensure that PHS-sponsored research will be conducted free of bias resulting from investigator financial conflicts of interest, as required by regulations on the Responsibility of Applicants for Promoting Objectivity in Research for which PHS Funding is Sought (42 CFR Part 50, Subpart F). The CSUN policy requires PHS-funded investigators, including those funded by the National Institutes of Health (NIH), to disclose significant financial interests that may constitute financial conflicts of interest. Much like the COI process, above, in the event an investigator discloses a significant financial interest, the Associate Vice President, Research and Sponsored Programs, or their designee, will determine whether a financial conflict of interest exists and will work with the investigator to develop a plan to manage the conflict of interest.

The FCOI disclosure and training requirements apply to Programs that are sponsored by components of the PHS or other agencies or organizations that have adopted the PHS requirements. The Federal Demonstration Partnership maintains a list of these agencies and organizations. (This list is subject to change.)

FCOI Disclosure Form

  • Complete this form to disclose Financial Conflict of Interest for PHS-funded projects
  • Submitted at the time of proposal submission, yearly thereafter, and within 30 days of acquiring a new significant financial interest
  • Required in addition to the CSUN COI Disclosure Form
  • Required of all principal investigators, co-principal investigators, and project directors involved in the project

FCOI Online Course

  • Investigators must complete the training prior to engaging in the sponsored research
  • The course must be retaken at least every four years
  • Required of all principal investigators, co-principal investigators, and project directors involved in the project

How to Complete the Online Course

1. Go to the Collaborative Institutional Training Initiative (CITI) website.
2. Login or register for a new account. (Be sure to select California State University, Northridge as your institution during the registration process.)
3. Once registered, add the Conflicts of Interest course to your queue.
4. Complete the course. The Collaborative Institutional Training Initiative will provide confirmation of successful completion of the course directly to the Office of Research and Sponsored Programs.

Public Health Service (PHS) Institutional Compliance Certification

Per NIH Notice Number: NOT-OD-06-054, the signature of the Principal Investigator is no longer required as a part of a submitted application. Instead, a new compliance requirement is now implemented whereby the applicant organization agrees to secure and retain at the organization a written assurance from the Principal Investigator (PI) prior to submitting an application to PHS agencies.

Also, per NIH Notice Number: NOT-OD-06-058 Progress reports submitted for due dates on/after June 1, 2006, the signature of the Principal Investigator is no longer required as a part of a submitted progress report. Instead, a new compliance requirement is now implemented whereby the grantee organization agrees to secure and retain at the organization a written assurance from the PI prior to submitting a progress report to PHS agencies.

While this assurance is no longer required as part of the submitted application or progress report, it remains a compliance requirement. Therefore, organizations must retain a unique signature and date for each submitted application and progress report. When multiple PIs are proposed in an application, these assurances must be retained for all named PIs. This assurance must be available to the sponsoring agency or other authorized HHS or Federal officials upon request.

Complete this form for the PHS/NIH Institutional Compliance Certification.

Refer to the following website to see a list of PHS agencies http://thefdp.org/default/fcoi-clearinghouse/fcoi-agencies/. Please be advised that there is a list of Non-PHS Agencies that follow this policy, and we will require the form per agency guidance and requirement.