PRO-U20.17A Disclosing Conflicts of Interest for Sponsored Programs and Technology Transfer Transactions

Action By:

Institutional Official (IO)

  1. Trains all Investigators participating in sponsored programs or activities where the sponsor, regulations, or other terms and conditions require the completion of training on the sponsor’s and University’s COI policies and as required by the IO, as appropriate. 

Investigator

  1. Discloses conflicts of interest prior to submission of any sponsored program proposals or within thirty (30) calendar days of acquiring new or increased conflict of interest (COI) using disclosure form on Research Integrity and Compliance website.
  2. For the duration of a sponsored project, disclose conflicts of interest to the Office of the Vice Provost for Research by January 15th of each calendar year.

Institutional Official

  1. Reviews the disclosures within thirty (30) calendar days in conjunction with sponsor COI policy to determine if the disclosed significant financial interest (SFI) constitutes a COI related to a sponsored project or technology transfer transaction.
  2. If the IO determines a COI exists, the IO reports the COI to the Conflict of Interest Review Committee. 

Conflict of Interest Review Committee

  1. Reviews the research proposal, the conflicts of interest in question, and the areas of conflict.
  2. Creates a COI management plan. The management plan may include:
    • conditions or restrictions to manage, reduce, or eliminate the COI
    • monitoring the research by independent reviewers
    • modification of the research plan, disqualification of participation in the portion of the federally-funded research that would be affected by COI
    • divestiture of the SFI
    • severance of relationships that create conflicts
    • public disclosure of the COI as required by sponsor
  3. Shares the determination and management plan with the IO and Investigator.
  4. Consults with Investigator about the implementation of the management plan; the Investigator must agree to the plan before proposal submission or before research can continue.

Investigator

  1. Implements management plan or appeals committee determination to the IO.
  2. May appeal the finding to the IO, if Investigator objects to the findings of COI or objects to the management plan proposed by the committee. The Investigator must file the appeal within fourteen (14) days of the committee’s finding.

Institutional Official

  1. Reviews the evidence, the determination of a COI and the committee’s management plan and determines whether to uphold the finding or reverse it.

Investigator

  1. Implements management plan upheld by the IO or continues proposal submission or research if no COI is found.

Office of the Vice Provost for Research

  1. Reports all financial conflicts of interest to sponsor(s) within sixty (60) days of discovery or as required by sponsor’s policy. The disclosure will include the name of the Investigator, the source of the COI, the amount of the FCOI, the management plan, and any other details required by sponsor.
  2. If required by sponsor, the institution will publicly post COIs on a routine basis and update postings annually or as needed. The posting will include the Investigator’s name, the source of the COI, the amount of the COI, and the management plan.

Investigator

  1. Discloses all newly acquired COIs that may relate to their research project within thirty (30) days of acquiring new or increased conflict of interest (COI).

Procedure Information

Approved By:

Vice Provost, RSP

Effective Date:

May 26, 2026

Authority:

Related Forms

No forms apply to this procedure.

Procedure Contact

Research and Sponsored Programs

Phone: (360) 650-3220

Research and Sponsored Programs website