Conflicts of Interest

Other Relevant University Policy

Reporting Other Support to Federal Agencies Policy

According to Federal requirements, institutions must maintain a written and enforced policy that ensures Senior/Key Personnel understand their responsibility to disclose all resources made available in support of and/or related to their research endeavors.  These Disclosures must include all domestic and foreign support, regardless of monetary value or institutional affiliation.

The UGA Reporting Other Support to Federal Agencies Policy applies to all UGA faculty, Senior/Key Personnel, and professional staff who are designated as Senior/Key Personnel on proposals to or awards from federal funding agencies that require Other Support training.  This policy ensures UGA’s institutional compliance with updated federal requirements and supports the responsible conduct of research by promoting transparency and accountability.

POLICY PROVISIONS

  1. Reporting Obligation:
    All investigators must disclose their current and pending research support and other support as required by each federal sponsor’s policies.  These Disclosures must be truthful, complete, and submitted in the format and timelines specified by the sponsor.
  2. Scope of Disclosure:
    Individuals must include all forms of research support—monetary or in-kind, domestic, or foreign—including support from internal UGA sources, consulting arrangements related to research, in-kind contributions, or facilities access.  Exempt items include gifts and prizes not tied to specific research activities.
  3. Format and Systems:
    Disclosures must be submitted using the appropriate sponsor system or form, such as SciENcv for NSF or the NIH Other Support template.  UGA requires compliance with sponsor-specific guidelines, including digital signature and certification requirements (e.g., PDF uploads with PI certification for NIH).
  4. Updates and Corrections:
    Investigators are responsible for updating their Disclosures during the life of the project if new support is received or previously undisclosed support is identified.  Updated information must be submitted as required by the sponsor (e.g., at Just-in-Time or during annual progress reports).
  5. Training and Internal Disclosure:
    Training and cadence will be developed and overseen by the Office of Research.  UGA faculty and administrative professionals must also comply with institutional reporting policies.  These Disclosures are required annually, with additional updates as needed.
  6. Consequences of Noncompliance:
    Failure to disclose required information may lead to sponsor-imposed penalties, including suspension or termination of awards, as well as institutional disciplinary action under UGA policies.

Contact

Gene Pope, Director, Conflicts of Interest, Office of Research, gene.pope@uga.edu

Tina Bosworth, Director of Research Security & Export Controls, tina.bosworth@uga.edu

Familial Relationships with UGA Collaborators

The UGA Conflicts of Interest, Conflicts of Commitment, and Outside Activities Policy requires that:

“UGA employees have an ongoing responsibility to report and fully disclose any personal … relationship that has the potential to create an actual or apparent conflict of interest with respect to the employee’s UGA duties ….”

Under the policy, “An apparent conflict exists when a reasonable person would conclude from the circumstances that the employee’s ability to protect the public interest, or perform public duties, is compromised by a personal, financial, or business interest.”

This Policy applies to research collaborations where there is a familial relationship between an Employee, e.g., Senior/Key Personnel, co-PI, researcher, etc., and the PI or co-PI, even if the related individuals do not otherwise fall within the same line of authority outside of the proposed project.  PIs are responsible for the overall administration and oversight of a sponsored project, including financial transactions, even if the relative is not otherwise in the PI’s typical line of authority.

To ensure transparency and preserve the public trust in the research conducted at the University, a management plan may be required.  The basic requirements of the plan are confirmation that 1- the PI’s family member has the necessary qualifications, knowledge, skills, and abilities to be included as project personnel and 2- the proposed effort and budget for the PI’s family member is equivalent to that for other, similarly situated individuals.  The management plan requires the academic unit to ensure that the PI does not control the relative’s scheduling, timekeeping or other payroll functions, or any expenditures of project funds on the relative, such as purchases and travel.

Please understand that the implementation of a management plan in these scenarios is neither an implication of “bad behavior” on the part of the family members nor meant to discourage familial collaborative research.

Contact

Gene Pope, Director, Conflicts of Interest, Office of Research, gene.pope@uga.edu, 706-542-3821

Prohibition on Transacting Business with the State

Companies in which an employee has a substantial interest may not do business with UGA. Under Georgia state law, substantial interest “means the direct or indirect ownership of more than 25 percent of the assets or stock of any business.” An employee’s company is prohibited from subcontracting from UGA or consulting for UGA (i.e., selling services to UGA).  In addition, the company cannot sell or lease personal or real property to UGA or purchase surplus, real or personal property from UGA.

Employee Guidance Contact
Office of Legal Affairs, 706-542-0006