Conflict of Interest

Policies & Procedures

USF Disclosure Review & Management Procedures

For USF Research Projects (General)

Applies to the receipt, assignment, review, distribution and maintenance of significant Financial Interests and Relationships disclosures submitted to the Conflict of Interest Committee for review and adjudication.  

For USF Resarch Projects Funded by Federal Agencies 
(including Certain Agencies, Foundations and Extramural Sponsors)

Applies to the receipt, assignment, review, management, distribution and maintenance of Significant Financial Interest Disclosures of Investigators participating in USF Research Projects per USF Policy 0- 309: Individual Conflicts of Interest in USF Research Projects and USF Financial Conflicts of Interest.

For USF Research Projects Involving a Person Related to the Investigator

When a USF Investigator employs another USF Investigator who meets the definition of Related Person per USF Policy 0-309, the Principal Investigator must disclose the relationship to the University.
USF Conflict of Interest Policies

US Policy 0-309:
Individual Conflicts of Interest in US Research Projects and USF Financial Conflicts of Interest

Ensures that that any Conflict of Interest that an Investigator may have in connection with a USF Research Project is fully disclosed, reviewed in accordance with established procedures, and satisfactorily resolved before the USF Research Project is initiated, regardless of funding source or status.

US Policy 0-317: 
Institutional Conflicts of Interest in USF Research Projects and USF Financial Conflicts of Interest

Protects against exposure from risk related to an institutional conflict of interest in which the financial interests of an institution or institutional official, acting within his or her authority on behalf of the institution, may affect or appear to affect the research conducted under the auspices of the institution. 
PHS and NSF Subrecipient Conflict of Interest Disclosure Process
You are a proposed subrecipient or consultant on a proposal that the University of South Florida intends to submit for funding from the National Science Foundation (NSF) or one of the Public Health Service (PHS) or other agencies who have adopted the PHS Objectivity in Research regulation (see list of agencies). Federal regulations require us to collect certain information from you at time of proposal and during the life of the award.

Step 1: Complete Form A

If you are a Subrecipient Authorized Organization Official OR subrecipient investigator OR consultant investigator, please complete Form A via the electronic USF Subrecipient COI Disclosure Form System. This form must be on file before the University of South Florida can submit a proposal containing your proposed subaward.

Please note: for projects subject to the PHS Objectivity in Research regulation, if your institution is a proposed subrecipient and is on the COI Terms and Conditions page on our website list of institutions with a PHS-compliant Conflict of Interest (COI) policy, you do NOT need to submit Form A. Per the regulation, you must report any FCOI to the University of South Florida in the timeline specified in 42 CFR Part 50. In contrast, each consultant considered to be an Investigator (anyone responsible for the design, conduct or reporting of the research) must submit Form A as a declaration of whether s/he is following his/her own institution's compliant COI policy or the University of South Florida's COI Policy.

Step 2: Complete Form B

If, and only if, you or an Authorized Organizational Official at your institution indicates on Form A that the University of South Florida's COI Policy will be followed (because your organization does not have its own NSF or PHS-compliant COI policy), then EACH subrecipient Investigator (defined as a person responsible for the design, conduct or reporting of the research proposed under the subaward) must be listed on Form A and complete Form B, the financial disclosure form.

Form A will prompt you to "Notify All" Investigators listed, which will send a system-generated email with a personalized link to Form B to each Investigator. If you are a consultant and you are not affiliated with an institution that has a NSF or PHS-compliant COI policy, then you must list yourself as an Investigator on Form A and complete Form B, as well. As part of Form B, each Investigator must certify that they have completed USF's Financial Conflict of Interest Training for Subrecipients (PDF). Training must be repeated at least every three years.

Step 3: Submit Financial Conflict of Interest Report

For projects subject to the PHS Objectivity in Research Regulation, if you or the Authorized Organizational Official indicates that your institution's COI policy will be followed, and if the COI Official at your institution determines that one or more Investigators on this project has a Financial Conflict of Interest (FCOI, as defined in the PHS regulation) related to the project, then your institution must submit all information required for submission of an FCOI report to the University of South Florida's Conflict of Interest Program, by email, according to the following:

  • For new awards, information on identified FCOIs must be submitted prior to execution of the subagreement;
  • For disclosure of Significant Financial Interests (SFI, as defined in the PHS regulation) made during the course of an award, information on an identified FCOI must be submitted within 45 days of your institution receiving the pertinent Investigator's disclosure.

The following information is required for an FCOI report:

  • Name of the Investigator with an FCOI;
  • Name of the entity with which the Investigator has an FCOI;
  • Nature of the financial interest (e.g., equity, consulting fee, travel reimbursement, honorarium);
  • Value of the financial interest, or a statement that the interest is one whose value cannot be readily determined through reference to public prices or other reasonable measures of fair market value;
  • A description of how the financial interest relates to the PHS-funded research and the basis for your institution's determination that the financial interest conflicts with such research; and
  • A description of the key elements of your institution's management plan, including:
    • Role and principal duties of the conflicted Investigator in the research project;
    • Conditions of the management plan;
    • How the management plan is designed to safeguard objectivity in the research project;
    • Confirmation of the Investigator's agreement to the management plan;
    • How the management plan will be monitored to ensure Investigator compliance; and
    • Other information as necessary.
Interest Inventories