Other Research Support, Conflict of Interest, and International Collaborations

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Other Research Support refers to information about an investigator’s research support that is currently active or pending review. This information may be due at the time a proposal is submitted or required prior to an award is made.

Investigators are responsible for including all sources of support consistent with the sponsor’s requirements. Additionally, some sponsors may require disclosures of conflict of interest as well as work and collaborations outside the U.S.

Outlined below are current requirements for reporting other support, financial conflict of interest, and foreign collaborations and support to the NIH and the NSF.

 

NIH

NSF

Other Support

All positions & appointments with entities outside CSU, whether remuneration is received or not, must be reported under NIH Other Support.

 

Additionally, substantive, measurable support received from an entity outside CSU must be reported, including in-kind support (e.g., office/lab space, equipment, supplies, employees).

All titled positions must be identified under ‘Appointments’ in the NSF Biographical Sketch regardless of remuneration.

 

All resources made available to an investigator in support of their research, regardless of monetary value or if support is directed through the institution or provided directly to the investigator, should be listed in the Current and Pending Support document. This included in-kind contributions, whether intended for use on the project being proposed.

 

In-kind contributions for use on the project being proposed should be reported under Facilities, Equipment, and Resources.

Financial COI (fCOI)

*All significant financial interest (aggregate value of $5K or greater) must be disclosed to CSU annually and as interests arise (NIH fCOI).

 

Travel reimbursed or sponsored by entities outside of CSU must be disclosed (excluding domestic IHE and Federal, state, or local governments).

*All significant financial interest (aggregate value of $5K or greater) must be disclosed to CSU annually and as interests arise (NSF COI).

 

Travel reimbursed or sponsored by entities outside of CSU must be disclosed (excluding domestic IHE and Federal, state, or local governments).

Grants to Foreign Institutions, International Organizations, and Domestic Grants with Components

Disclosure requirements include any significant scientific element or segment of a project completed outside the U.S., whether or not paid by NIH funds, must be reported.

Disclosure requirements include any significant scientific element or segment of a project completed outside the U.S., whether or not paid by NSF funds, must be reported.

It is up to the Investigator and key personnel to properly report all sources of research support. Failure to report other sources of support, whether internal or extramural, domestic, or foreign, can lead to a loss of funding, and in some instances, prosecution by the sponsoring agency.

Best practices in disclosures to sponsors include:

§  Report all sources of support consistent with the funding agency’s requirements.

§  Be thorough and complete in accounting for all forms of research support, whether gifts, grants, or other sources of support.

*It is a CSU requirement that faculty and administrative professional personnel disclose financial and outside professional activities through the Kuali COI module. Currently, CSU requires annual disclosures, though it is important to be aware that reporting windows, thresholds, and requirements differ by sponsor. Disclosures should be updated as new events impacting COI occur. Waiting to report could lead to compliance issues.

Blog post by Kim Melville-Smith, Administration Compliance Manager, Office of Sponsored Programs