Conflict of Interest and Conflict of Commitment In Research Policy

Purpose

Northern Illinois University is committed to ensuring that our knowledge creative enterprise performed through research, scholarship, and creative activities are conducted with integrity, objectivity, transparency, and compliance with applicable federal regulations.

This Policy establishes institutional requirements for the identification, disclosure, review, management, and reporting of:

• Conflicts of Interest (COI)
• Financial Conflicts of Interest (FCOI)
• Conflicts of Commitment (COC)
• Organizational Conflicts of Interest (OCI)
• Foreign affiliations, appointments, and activities that may create research security concerns

This Policy is intended to comply with applicable federal sponsor requirements, including, but not limited to:

• Public Health Service (PHS) regulations governing financial conflicts of interest.
• Department of Energy (DOE) requirements regarding conflicts of interest, conflicts of commitment, organizational conflicts of interest, and research security.
• National Science Foundation (NSF) requirements related to conflict of interest, conflict of commitment, disclosure of Current and Pending (Other) Support, foreign affiliations and appointments, foreign talent recruitment programs, and certifications required under the CHIPS and Science Act and NSF Proposal and Award Policies and Procedures Guide (PAPPG).
• National Aeronautics and Space Administration (NASA) conflict of interest requirements.
• All other granting agencies conflict of interest and commitment regulations.

Scope

This Policy applies to all individuals responsible for the design, conduct, reporting, administration, oversight, or management of sponsored activities conducted on behalf of the Institution.

This includes:

• Faculty
• Staff
• Principal Investigators
• Co-Investigators
• Senior/Key Personnel
• Research administrators
• Subrecipient investigators when required by sponsor regulations

Policy Statement

The Institution requires all covered individuals to:

• Conduct sponsored activities free from undue bias.
• Avoid actual, potential, or apparent conflicts.
• Disclose outside interests, relationships, and commitments that may affect institutional responsibilities.
• Comply with sponsor disclosure requirements.
• Cooperate with institutional reviews and management plans.
• Protect research integrity and research security.

No individual may participate in sponsored activities when an unmanaged conflict exists that could compromise research integrity, institutional decision-making, sponsor compliance, or research security.

Authority and Oversight

The Institution delegates responsibility for implementation of this Policy to the Office of Research Compliance, Integrity, and Safety (ORCIS).

ORCIS shall:

• Administer disclosures
• Conduct conflict reviews
• Establish management plans
• Maintain records
• Report conflicts to sponsors when required
• Coordinate research security reviews

The Institution may establish a Conflict of Interest and Commitment Committee to assist with conflict determinations and management.

Disclosure Requirements

Covered individuals must disclose:

• Financial interests
• Outside professional activities
• Consulting activities
• Sponsored travel
• Leadership roles in external organizations
• Foreign and domestic appointments, affiliations, and positions, whether paid or unpaid
• External research support
• Participation in any foreign talent recruitment programs
• All Current and Pending (Other) Support required by sponsors
• Other interests and commitments that may reasonably create a conflict, or reasonable appearance of a conflict

Disclosures shall occur:

• Prior to proposal submission or project participation
• Annually
• Within the timeframe established by institutional procedures whenever material changes occur

Review and Management

The Institution shall review disclosures to determine whether:

• A Conflict of Interest exists
• A Financial Conflict of Interest exists
• A Conflict of Commitment exists
• An Organizational Conflict of Interest exists
• A research security concern exists

When necessary, conflicts shall be managed, reduced, or eliminated through a documented management plan. Management plans may include disclosure requirements, monitoring, recusal, reduction of outside activities, modification of project responsibilities, or other measures necessary to protect research integrity, sponsor compliance, and national security interests.

Training

Covered individuals shall complete conflict of interest and research security training as required by sponsor regulations and institutional procedures.

Reporting

The Institution shall report conflicts and related information to sponsors when required by law, regulation, or award terms.

Enforcement

Failure to comply with this Policy may result in:

• Corrective action
• Additional oversight
• Removal from sponsored projects
• Suspension of research privileges
• Employment-related disciplinary action
• Sponsor notification when required

Records

The Institution shall maintain records required by sponsor regulations and application institution retentions schedules.