Research conflicts of interest encompass several research related policies and guidelines. Key policies include the Policy on Conflicts of Interest in Sponsored Programs, the Policy on Institutional Conflicts of Interest in Human Subjects Research, and the Conflicts of Interest, Conflicts of Commitment, and Outside Activities Policy specifically when research, intellectual property, or startup activity is implicated. Additional relevant policies, as applied to sponsored research activities, includes the HR Employment of Relatives policy and the state law prohibition on transacting business with the state.
Policy on Conflicts of Interest in Sponsored Programs
UGA 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).
UGA applies the PHS requirements ONLY to those Investigators submitting to PHS units. However, all UGA investigators must use the DHHS/PHS Disclosure of Significant Financial Interests form when required to do so. As a reminder, all University employees must comply with UGA’s Policy on Conflicts of Interest in Sponsored Programs and must disclose any activity that might constitute a financial conflict of interest.
PHS Investigator Disclosures
- All PHS 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 PHS-funded projects, either funded or proposed”) 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 SFI or acquiring a new SFI.
- The Disclosure must cover all financial interests that have an annual monetary value of $5,000 or more, whether or not the value is readily ascertainable.
- The Disclosure must have been filed by the time of proposal submission for any proposal submitted on or after August 25, 2012.
- PHS regulations 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 eResearch Portal.
Non-UGA employees must complete the Annual Disclosure of Financial Interests for Non-University of Georgia Investigators.
Conflict of Interest training/education is required for all Investigators on PHS grant and cooperative agreement proposals. Training for UGA Investigators will be provided via the Professional Education Portal that UGA uses for Responsible Conduct in Research and Human Subjects training.
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.
Office of Research Integrity and Safety, Sponsored Projects Administration
Conflicts of Interest, Conflicts of Commitment, and Outside Activities Policy
The Conflicts of Interest, Conflicts of Commitment, and Outside Activities Policy is managed by colleges/schools/units and requires prior approval for compensated Outside Activities as well as disclosures of Conflicts of Interest to the college/school/unit.
Approvers of Outside Activity requests should be mindful of any YES answers on the form to questions 7a-f and forward the request to email@example.com before approving of the activity. The Office of Research will review these activities with a sponsored research, intellectual property, or startup nexus. The review includes guidance on approval, potential restrictions, or related conflict of interest management and is provided to colleges/schools/units by the Office of Research. Ultimate approval or imposition of restrictions or a management plan lies with colleges/schools/units.
Faculty Affairs, Human Resources, Office of Legal Affairs
Staff Policy Contact: Sige Burden, 706-542-9231
Faculty Policy Contact: Dr. Sarah Covert, 706-542-0547
Institutional Conflicts of Interest in Human Subjects Research
The Human Research Protection Program at the University of Georgia is committed to maintaining objectivity in the research enterprise, avoiding even the appearance of impropriety and ultimately protecting human subjects.
The Policy requires the annual disclosure of Significant Institutional Financial Interests by Institutional Leaders and quarterly disclosures by the Institution. The Office of Research Integrity and Safety reviews these disclosures, provides relevant disclosure details to the Human Research Protection Program, and assists in the review and management of Institutional Conflicts of Interest in Human Subjects Research Activity.
Human Research Protection Program
Startup Conflicts of Interest Guidance
Innovation Gateway and the Office of Research Integrity and Safety provides specific Startup Conflicts of Interest guidance. When contemplating the creation of a startup company, both the Conflicts of Interest, Conflicts of Commitment, and Outside Activities Policy and the Policy on Conflicts of Interest in Sponsored Programs can be implicated. When engaging in startup activities, UGA employees must continue to fulfill all their university obligations and may not utilize UGA resources for company work without both written approval and reimbursing the University. Startup activity must not begin until the Outside Activity is approved, and a conflict of interest is disclosed to your college/school/unit. Additionally, startup activity must be disclosed pursuant to the Policy on Conflicts of Interest in Sponsored Programs.
Innovation Gateway, Office of Research Integrity and Safety
HR Employment of Relatives Policy
Human Resources promulgates the Employment of Relatives Policy. This policy requires permission of the academic unit for Principal Investigators to employ a relative in a sponsored research project at UGA. This situation further requires a workaround of the Employment of Relatives Policy for the subordinate relative to participate. Principal Investigators are responsible for the overall administration and oversight of a sponsored project, including financial transactions, even if the relative is not otherwise in the Principal Investigator’s typical line of authority as a UGA employee. The workaround requires that the academic unit 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. Sponsored Projects Administration will require the academic unit’s approval of the relative’s participation and the unit’s implementation of a workaround before an award is made.
Sige Burden, 2-9231
Prohibition on Transacting Business with the State
Companies in which an employee has a substantial interest may not do business with UGA. 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, 2-0006