KSU's Conflict of Interest Committee (COIC) will review all SFI disclosures. If the COIC reasonably determines that an SFI constitutes a financial conflict of interest (FCOI), KSU will, in collaboration with the investigator, develop and implement a written conflict management plan (CMP) before any related sponsored funds may be expended. The CMP will specify actions to be taken to manage, reduce, or eliminate the FCOI.

Examples of conditions or restrictions that might be imposed in a CMP include:

• Public disclosure of the FCOI in presentations and publications.
• Modification of the research plan to mitigate the conflict.
• Appointment of an independent monitor to oversee the research.
• Disqualification from participation in the portion of the project related to the FCOI.

Training Requirements

All investigators must complete FCOI training:

• Prior to engaging in sponsored research.
• At least once every four (4) years.
• Immediately, if KSU revises this policy, an investigator is new to KSU, or an investigator is found to be non-compliant with this policy.

Subrecipient and Collaborator Compliance

KSU will take reasonable steps to ensure that any subrecipient, contractor, or collaborator on a KSU-administered sponsored project complies with federal FCOI regulations. This will be achieved by establishing a written agreement that requires the subrecipient to either certify that its own FCOI policy is compliant with federal regulations or agree to abide by this KSU policy.

Public Accessibility

In accordance with federal regulations, KSU will make information concerning identified FCOIs held by senior/key personnel on PHS-funded projects publicly accessible upon written request.

Non-Compliance and Enforcement

Failure to disclose an SFI in a timely manner or to adhere to a mandated CMP constitutes non-compliance with this policy. Non-compliance may result in administrative sanctions, loss of eligibility to participate in sponsored projects, and/or other disciplinary action. In cases of confirmed non-compliance involving PHS-funded research, KSU will conduct a retrospective review and submit a mitigation report to the PHS as required by regulation.

Record Retention

ORI shall retain all SFI disclosures, FCOI reviews, CMPs, and related documents for a period of at least three (3) years from the date of submission of the final expenditures report for the applicable sponsored project.

REFERENCES AND RELATED MATERIALS:

• 42 CFR Part 50, Subpart F: Promoting Objectivity in Research
• 45 CFR Part 94: Responsible Prospective Contractors
• NSF Proposal & Award Policies & Procedures Guide (PAPPG), Chapter IX.A
• Institutional Ethics and Code of Conduct

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