National Science Foundation Conflict of Interest Disclosure

NSF COI Requirements for Investigators

The National Science Foundation (NSF) requires that investigators disclose all significant financial interest that are held personally or by a spouse or dependent:

• That would reasonably appear to be affected by the research or educational activities funded or proposed for funding by NSF.
• In entities whose financial interest would reasonably appear to be affected by such activities.

This requires anyone responsible for the design, conduct, or reporting of research or educational activities funded or proposed for funding by the NSF to complete disclosure.

Guidance

Significant Financial Interests to Report

Significant financial interests to report include, but are not limited to:

• Salary or other payments for services (e.g., consulting fees or honoraria).
• Equity interest (e.g., stocks, stock options, or other ownership interest).
• Intellectual property rights (e.g., patents, copyrights, and royalties from such rights).

Financial Interest that does not Require Reporting

Financial interests that do not require reporting include:

• Salary, royalties, or other remuneration from the applicant organization.
• Income from seminars, lectures, or teaching engagements sponsored by public or non-profit entities.
• Income from service on advisory committees or review panels for public or nonprofit entities.

How to Comply

Disclosure of Significant Financial Interest

Investigators must provide all required financial disclosures at the time the proposal is submitted to NSF and must recertify their disclosure on an annual basis, or as new reportable significant financial interest are obtained.

The RCOI Disclosure form is fully electronic and accessible here: https://mentis.uta.edu/public/#coi/index/index

PHS and DOE investigators: Financial Disclosure and Training Requirements

FCOI Compliance

The Department of Health and Human Services (DHHS- PHS and components of PHS), through its regulation 42 CFR Part 50 Subpart F, and the Department of Energy (DOE), through its Interim Conflict of Interest Policy Requirements for Financial Assistance, require additional compliance steps relative to Financial Conflicts of Interest.

All “Investigators”- the PI, Co-I, senior/key personnel, and anyone- regardless of title or position- who is responsible for the purpose, design, conduct, or reporting of the sponsored research- are required to complete training on Financial Conflicts of Interest and disclose Significant Financial Interests.

How to Comply

FCOI Training

Investigators on PHS or DOE awards must complete a university approved Financial Conflicts of Interest in research training prior to engaging in research and thereafter, every four years and immediately when any of the following circumstances apply:

• The institution revises its financial conflict of interest policies or procedures in any manner that affect the requirements of the investigators.
• An investigator is new to the institution; or
• An institution finds that an investigator is not in compliance with the institution’s financial conflict of interest policy or management plan.

The required training is fully online and is accessible here: https://mentis.uta.edu/public/#trn/index/index

Disclosure of Significant Financial Interest

A significant financial interest (SFI) is a financial interest of the investigator’s or those of the investigator’s spouse or dependent children, that reasonably appears to be related to the investigator’s institutional responsibilities.

You must disclose your SFI and SFIs of your spouse and dependents when your funding proposal is submitted to the university or before you work on an award subject to additional FCOI compliance. You must update your disclosure annually and within 30 days of any newly acquired or discovered SFIs.

The RCOI Disclosure form is fully electronic and accessible here: https://mentis.uta.edu/public/#coi/index/index

Examples of Significant Financial Interests required to be reported:

• Regarding any foreign or domestic PUBLICLY traded entity:
  • Equity interest or remuneration, income, salary, or any payment for services, when totaled, is valued at $5,000 or more per calendar year (Consulting fees, honoraria, paid authorship, stock, stock option, or other ownership interest).
  • Value of remuneration + equity interest > $5,000.
• Regarding any foreign or domestic NON-PUBLICLY traded entity:
  • ANY amount of equity interest (stock, stock option, or other ownership interest, i.e. sole proprietorships, co-founding a start-up, etc.).
  • Remuneration (income, salary, or any payment for services) valued at $5,000 or more per calendar year.
  • Value of remuneration > $5,000 OR ANY amount of equity interest.
• Regarding Intellectual Property:
  • Patents not assigned to UTA.
  • Licenses from the UTA to external entities.
  • Copyrights.
  • Royalties that are not paid by UTA.
• Other:
  • Fiduciary Roles, even if unpaid.
  • Sponsored or reimbursed travel of $5,000 or more (when aggregated per entity) in the preceding 12 months.

Interests Exempt from Reporting Requirements

Exemptions

• Salary, royalties, or other remunerations paid through the Institution to the Investigator if the Investigator is currently employed or otherwise appointed by the Institution.
• Income from investment vehicles (mutual funds or retirement accounts that are not managed directly by the individual).
• Income from seminars, lectures, or teaching engagements sponsored by a US federal, state, or local government agency, a U.S. Institution of higher education as defined by 20 U.S.C. 1001(a); an academic teaching hospital, a medical center, or a research institute that is affiliated with a U.S. institution of higher education.
• Income from service on advisory committees or review panels for a US federal, state, or local government agency, a U.S. institution of higher education as defined by 20 U.S.C. 1001(a). (e.g., NIH review panel).
• Travel that is reimbursed or sponsored by a US federal, state, or local government agency, a U.S. institution of higher education as defined by 20 U.S.C. 1001(a); an academic teaching hospital, a medical center, or a research institute that is affiliated with a U.S. institution of higher education.