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)
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.
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 https://thefdp.org/demonstrations-resources/fcoi-clearinghouse/?highlight=phs+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.
