In addition to the College’s standard policies on Ethics and Conflict of Interest, and Paid Outside Activities, faculty and staff supported by federal funding from the National Science Foundation and the National Institutes of Health must complete additional training, and provide specific conflict of interest disclosures, in order to be compliant with federal requirements. These requirements –Financial Conflict of Interest Disclosure in Research and Responsible Conduct of Research (RCR) Training, are described below.
Financial Conflict of Interest (FCOI) Disclosure in Research
Both the National Science Foundation (NSF) and the National Institutes of Health (NIH) require conflict of interest disclosures from from all investigators who are defined as the principal investigator, co-principal investigators/co-project directors, and any other person at the College who is responsible for the design, conduct, or reporting of research or educational activities funded by an NSF or NIH grant. The COI screening questions are required to be completed by all persons who certify as a PI or Co-I. Those screening questions are in compliance with NSF/NIH requirements for disclosure and Emerson's FCOI policy.
What must be disclosed?
The NSF requires each investigator disclose all “significant financial interests” of the investigator (including those of the investigator’s spouse and dependent children): (i) that would reasonably appear to be affected by the research or educational activities funded or proposed for funding by NSF; or (ii) in entities whose financial interests would reasonably appear to be affected by such activities.
"Significant financial interest" means anything of monetary value, including, but not limited to, salary or other payments for services (e.g., consulting fees or honoraria); equity interest (e.g., stocks, stock options or other ownership interests); and intellectual property rights (e.g., patents, copyrights and royalties from such rights), but does not include
- salary, royalties or other remuneration from the applicant organization;
- any ownership interests in the organization, if the organization is an applicant under the Small Business Innovation Research Program or Small Business Technology Transfer Program;
- income from seminars, lectures, or teaching engagements sponsored by public or non-profit entities;
- income from service on advisory committees or review panels for public or nonprofit entities;
- an equity interest that, when aggregated for the investigator and the investigator’s spouse and dependent children, meets both of the following tests: does not exceed $10,000 in value as determined through reference to public prices or other reasonable measures of fair market value, and does not represent more than a 5% ownership interest in any single entity; or
- salary, royalties or other payments that, when aggregated for the investigator and the investigator’s spouse and dependent children, are not expected to exceed $10,000 during the prior twelve-month period.
NIH more strictly defines a significant financial interest as remuneration or equity interest in any private or publicly traded entity that exceeds $5,000 in 12-month period, as well as certain occurrences of reimbursed or sponsored travel from outside entities (other than institutes of higher education, governmental agencies, or research/medical institutes affiliated with an IHE).
When are disclosures required?
Emerson requires that investigators subject to FCOI requirements must report whether or not they have significant financial interests related to their institutional responsibilities according to the following schedule:
- At the time of application for sponsored funding,
- At least annually thereafter during the period of research activity, with submittal of the annual disclosure coinciding with the due date of the project’s Progress Report, and
- At any time during the research within thirty days of the discovery or acquisition of a new reportable financial interest.
What happens if a potential conflict is disclosed?
All Disclosures are reviewed by a designated institutional representative (DIO) prior to any spending on the award. If no conflict exists, or if a satisfactory COI Management Plan is put into place prior to any spending, no review or approval outside of the College is required.
More Information
Emerson Financial Conflict of Interest in Research Policy
National Science Foundation Conflict of Interest Policy
National Institutes of Health Conflict of Interest Policy
Responsible Conduct of Research (RCR) Training
Training in responsible conduct of research (RCR) is a requirement for certain types of personnel receiving salaries or stipend support on specific NIH and NSF awards. Emerson provides access to this training online via the Collaborative Institutional Training Initiative (CITI). Additionally, NIH-funded investigators must complete Conflict of Interest (COI) training.
All required training must be completed before funds awarded by NSF or NIH may be utilized. The following table outlines the specific training requirements for each sponsor.
| Award Type | Required Training | Applies To | Deadline | Frequency |
|---|---|---|---|---|
| NIH Grant | Responsible Conduct of Research (RCR): Full Course | Key Personnel (PI’s, Co-PI’s, Post-Docs) | Prior to engaging in research funded by NIH | Once every four years |
| NIH Grant | Conflicts of Interest Training | Faculty (PI’s, Co-PI’s, Investigators) | Prior to engaging in research funded by NIH | Once every four years |
| NSF grant | Responsible Conduct of Research (RCR): Full Course | All students, postdoctoral researchers, faculty, and other senior personnel supported by the grant | Prior to engaging in research funded by NSF | Once every four years |
Accessing the Courses
To complete the training(s), please visit the CITI website and complete the following steps:
- Click on “New Users Register Here”: Follow the prompts to register and affiliate yourself with Emerson College. This is essential so that Emerson receives proof of your completion of training via a system generated notification.
- Select the appropriate course(s) (e.g., Responsible Conduct of Research, Conflicts of Interest).
- Complete the online readings and quizzes. You may log in and out of the system as many times as you need. It is recommended that you NOT try to complete the training in a single session. Each time you log in, you will be able to continue from where you previously left off. You can repeat quizzes and readings as many times as needed.
More Information
NIH Guidance on Requirement for Instruction in the Responsible Conduct of Research