Conflicts of Interest

Policy on Conflicts of Interest in Sponsored Programs

The Policy on Conflicts of Interest in Sponsored Programs complies with U.S. Department of Health and Human Services (DHHS) regulations for all Public Health Services (PHS) units, including the NIH, CDC, FDA, Indian Health Service (IHS), Health Resources and Services Administration (HRSA), and the Agency for Healthcare Research and Quality (AHRQ); the U.S. National Science Foundation (NSF) Conflict of Interest Policy; and the U.S. Department of Energy (DOE) Interim Conflict of Interest Policy.

All UGA investigators must submit a Disclosure of Significant Financial Interests form when required to do so. All investigators must comply with Policy on Conflicts of Interest in Sponsored Programs and must disclose any activity that might constitute a financial conflict of interest.  PHS and DOE investigators must submit a Disclosure of Significant Financial Interests, even if to report that they have no related outside activities.

Non-UGA investigators that meet the following:  1- the investigator will participate in a proposal submitted by UGA to PHS, NSF, or DOE and 2- the investigator’s employer does not have a conflict of interest policy that complies with PHS, NSF, and DOE requirements, must complete the Annual Disclosure of Financial Interests for Non-University of Georgia Investigators.

PHS and DOE Investigator Disclosures

  • All PHS and DOE investigators (defined as “the Project Director or Principal Investigator and any other person, regardless of title or position, who is responsible for the design, conduct, or reporting” of the research) are covered.
  • Investigators must file an annual Disclosure of Significant Financial Interests (SFIs) that is retrospective rather than prospective, covering the 12-month period prior to a proposal’s submission. A disclosure update is required within 30 days of discovering the presence of an unreported Significant Financial Interest (SFI) or acquiring a new SFI.
  • The Disclosure must cover all financial interests, including remuneration, consulting fees, etc., that have an annual monetary value of $5,000, stocks held in publicly-traded entities that are in the same field of expertise when the stocks have a value of $5,000 or more more, any equity in a privately-held company, including startups based on UGA research and intellectual property. 
  • The Disclosure must be completed by the time of proposal submission.
  • PHS regulations and DOE Policy apply to competing continuation awards. Your out year awards will be held up if you have not filed a disclosure in the previous 12 months or if you have not completed the FCOI training. Pending awards will be allowed to proceed for a subaward for any period prior to you having met the required disclosure and training requirements.

UGA employees disclose in the Sponsored Projects Administration Grants Portal.

FCOI Training

Conflict of Interest training/education is required for all investigators on PHS and DOE grant and cooperative agreement proposals. Training for UGA investigators is provided via the Professional Education Portal.

Training must be completed prior to an expense being recorded in UGA’s official records (i.e., training is not required at proposal time but must have been completed by award time). Refresher courses are required every four (4) years.

Training Contact
Lisa Kelly, Office of Research Integrity and Safety Support Services,, 706-583-0816 

Policy Owner
Office of Research Integrity and Safety, Sponsored Projects Administration

Policy Contact
Gene Pope, Office of Conflicts of Interest Review & Management,, 706-542-3821
Cathy Cuppett, Sponsored Projects Administration,, 706-542-9441