Conflict of Interest

COI Terms and Conditions

When to contact the COI Program

Sponsors are increasingly including COI terms in proposal and award documents. COI certifications are sometimes required prior to proposal submission. This may require the COI program to provide the sponsor with a management plan in the proposal submission or to request a waiver in advance of the proposal to allow for a submission with a COI present. Contact the COI program as soon as possible when you identify language that requires a COI certification at the time of proposal submission.

The COI program reviews SBIR/STTR proposals prior to submission and must receive those referrals from departments and/or Sponsored Research administrators during the letter of support preparation process via email.

Award terms including conflict of interest requirements must be referred to the COI program for review prior to award set-up and spending (see special notes below regarding NSF and sponsors that comply with the U.S. PHS regulation for objectivity in research).

Disclosure requirements for nepotism and significant financial interests (individual and institutional) related to research are available on the COI program's Policies and Procedures page.

COI Program Contact - Email or telephone: 813-974-5638

National Science Foundation (NSF)

NSF awards are routed to the COI program by Sponsored Research for review to ensure compliance with the PAPPG. For proposals to NSF, USF Investigators must have a current Interest Inventory submitted through ARC and subrecipient Investigators must submit USF Subrecipient COI Disclosure Forms A/B prior to proposal submission.

If a program announcement (e.g. PFI-AIR:TT) includes additional COI terms, please refer those to the COI program.

U.S. Public Health Service (PHS)

The U.S. Public Health Service (PHS) regulation for objectivity in research (42 CFR Part 50 Subpart F) is incorporated into all PHS proposals and awards (agencies listed below). In addition, several private foundations have adopted the PHS regulation (listed below). For proposals to these entities, USF investigators must have a current Interest Inventory submitted through ARC and subrecipient investigators must submit USF Subrecipient COI Disclosure forms A/B prior to proposal submission (except when the subrecipient entity is on the FDP FCOI Clearinghouse). Awards from the following entities are routed to the COI program by Sponsored Research for review. If there are additional requirements beyond the PHS terms (e.g. PCORI), contact the COI program directly.

PHS agencies (identified from the Department of Health and Human Services Organizational Chart):

  • Agency for Healthcare Research / Quality (AHRQ)
  • Agency for Toxic Substances and Disease Registry (ATSDR)
  • Centers for Disease Control and Prevention (CDC)
    • National Institute for Occupational Safety & Health (NIOSH)
  • Food and Drug Administration (FDA)
  • Health Resources and Services Administration (HRSA)
    • Bureau of Health Professions
    • Maternal and Child Health Bureau
    • National Center for HIV Care in Minority Communities
  • Indian Health Service (IHS)
  • National Institutes of Health (NIH)
    • NIH Office of the Director
    • National Cancer Institute (NCI)
    • National Eye Institute (NEI)
    • National Heart Lung and Blood Institute (NHLBI)
    • National Human Genome Research Institute (NHGRI)
    • National Institute on Aging (NIA)
    • National Institute Alcohol Abuse and Alcoholism (NIAAA)
    • National Institute of Allergy and Infectious Diseases (NIAID)
    • National Institute of Arthritis and Musculoskeletal and Skin Diseases (NIAMS)
    • National Institute of Biomedical Imaging and Bioengineering (NIBIB)
    • National Institute of Child Health and Human Development (NICHD)
    • National Institute on Deafness and Other Communication Disorders (NIDCD)
    • National Institute of Dental and Craniofacial Research (NIDCR)
    • National Institute of Diabetes and Digestive and Kidney Diseases (NIDDK)
    • National Institute on Drug Abuse (NIDA)
    • National Institute of Environmental Health Sciences (NIEHS)
    • National Institute of General Medical Sciences (NIGMS)
    • National Institute of Mental Health (NIMH)
    • National Institute Minority Health & Health Disparities (NIMHD)
    • National Institute of Neurological Disorders and Stroke (NINDS)
    • National Institute of Nursing Research (NINR)
    • National Library of Medicine (NLM)
    • Center for Information Technology (CIT)
    • Center for Scientific Review (CSR)
    • John E. Fogarty International Center (FIC)
    • National Center for Complementary and Integrative Health (NCCIH)
    • National Center for Advancing Translational Science (NCATS)
    • NIH Clinical Center (CC)
  • Office of Global Affairs
  • Office of the Assistant Secretary for Preparedness and Response (ASPR)
    • Biomedical Advanced Research and Development Authority (BARDA)
  • Substance Abuse & Mental Health Services Administration (SAMHSA)

Entities that have adopted the PHS regulation:

  • Alliance for Lupus Research
  • American Asthma Foundation
  • American Cancer Society
  • American Heart Association
  • American Lung Association
  • Arthritis Foundation
  • California Breast Cancer Research Program
  • California HIV/AIDS Research Program
  • CurePSP
  • Juvenile Diabetes Research Foundation
  • Lupus Foundation of America
  • Patient Centered Outcomes Research Institute (PCORI) (requires Interest Inventories, USF Subrecipient COI Disclosure Forms and additional review by the COI Program)
  • Susan G. Komen Breast Cancer Foundation
  • Tobacco-Related Disease Research Program

Last updated: 12/8/2017