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Conflict of Interest

Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards - Conflict of Interest

1. Ref.: 2 CFR Part 200.112, 45 CFR Part 50 Subpart F, RCW Chapter 42.52.020

2. Effective Date: April 21, 2015

3. Originating Office/Agency: Office of Management and Budget, U.S. Public Health Service, Washington State Legislature

4. Key Words: administrative requirements; responsible conduct in research; conflict of interest; financial conflicts of interest, FCOI, objectivity in research; investigator responsbilities

Eastern Washington University (EWU) has the responsibility to ensure that all faculty, staff, and any other person who conducts research activities under the auspices of the university adhere to ethical standards in managing potential conflicts of interest.

Under the Uniform Guidance, each Federal agency that awards and administers grants and agreements subject to the guidance is responsible for implementing standards and ensuring that recipients and subrecipients comply with the agency's implementation of the guidance.  In 2 CFR 200.112, it is specified that the Federal awarding agency must establish conflict of interest policies for all Federal awards, and that the non-Federal entity and pass-through entity must disclose in writing any conflict of interest in accordance with the Federal awarding agency policy. In addition, the Washington State Legislature, as part of the Ethics in Public Service Law, stipulates that no state officer or state employee may have an interest, financial or otherwise, direct or indirect, or engage in a business or transaction or professional activity, or incur an obligation of any nature, that is in conflict with the proper discharge of the state officer's or state employee's official duties.

The United States Public Health Service (PHS) has implemented Financial Conflict of Interest regulations, which are the standard that many agencies, both public and private, adhere to. The purpose of these regulations is to promote objectivity in research by establishing standards for design, conduct, and reporting of scholarly activities and research.

Recognizing that each Federal awarding agency may have a different policy regarding conflicts of interest, EWU has implemented a standard policy in a manner consistent with the guidance to ensure compliance. The Conflict of Interest Policy will apply to all awards regardless of the funding mechanism.

Summary of Conflict of Interest policies and procedures:

  • EWU will have in effect an up-to-date, written, enforced policy that complies with all applicable regulations which is available via the university website.
  • EWU will maintain a current enforceable written policy for disclosing and managing all conflicts of interest for each award regardless of the funding source.
  • EWU has the responsiblity and authority to take actions necessary to manage any potential financial conflict of interest relating to all research activities at the institution.
  • The Office of Grant and Research Development (OGRD) is the primary point of contact, and is responsible for managing matters related to financial conflicts of interest.
  • The OGRD will provide guidelines to identify conflicting interest related to proposed research.
  • All significant financial conflicts of interest of an investigator must be disclosed prior to the submission of a proposal for funding.
  • If a Significant Financial Interest (SFI) is identified and determined to be a Financial Conflict of Interest (FCOI), it must be satisfactorily managed, reduced, or eliminated prior to the expenditure of funds on any subsequent award.
  • If a new reportable SFI develops at any time following the submission of a proposal but prior to expenditure of funds, the filing of a new disclosure is also required. The OGRD will also adhere to the sponsor's reporting schedule as applicable.
  • The OGRD will update financial disclosures during the period of the award as indicated by the sponsor.
  • For PHS funded research, the OGRD will make certain required information available concerning FCOI's held by senior/key personnel to the public either via the university website, or in response to a written request within five business days of the request.
  • For any sub-award or pass-through entity, the OGRD will incorporate as part of a written agreement, terms that establish whether the FCOI policy of the awardee institution or that of the subrecipient will apply to subrecipient investigators and include time periods to meet SFI disclosure if applicable, as well as FCOI reporting requirements.
  • EWU will designate appropriate institutional official(s) to solicit and review disclosure statements from each investigator planning to participate in, or who is participating in research.
  • The OGRD will maintain records of all investigator disclosures of financial interests and the institution's review of and response to such disclosures, (whether or not a disclosure resulted in the institution's determination of FCOI) and all actions under the institution's policy or retrospective review, if applicable for the required period of time as indicated by the sponsor.
  • EWU will designate appropriate institutional official(s) to develop management plans that specify the actions that have been, and shall be, taken to manage a FCOI.
  • The OGRD will inform each investigator of the:
  1. Regulation(s);
  2. Institution's policy on FCOI; and
  3. Investigator's responsibilities regarding disclosure of SFIs
  • For PHS funded research, the OGRD will require that each investigator complete FCOI training:
  1. Prior to engaging in research related to any PHS/NIH funded project;
  2. At least every four years, and
  3. Immediately when any of the following circumstances apply:

      a. When the institution revises its policy in a manner that affects the investigator;

      b. When an investigator is new to the institution; or

      c. When the institution finds an investigator is not in compliance with EWU's policy or management plan.

  • The OGRD will certify in each application for funding submitted that the institution:
  1. Agrees to make information available upon request relating to any investigator disclosure of financial interest and the institution's review of, and response to, such disclosure, whether or not the disclosure resulted in the institution's determination of an FCOI.
  2. Will fully comply with the requirements of the regulations that apply to the funding entity.

Additional Applicable Regulations

NIH Financial Conflict of Interest Policy

NSF Conflict of Interest Policies

Summary of Conflict of Interest Policies

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