NSF Policy
PHS Policy

Conflict of Interest Certification Regarding PHS and NSF Sponsored Research

As of October 1, 1995 the Public Health Service (PHS) and the National Science Foundation (NSF)required institutions which apply for research funding from these agencies to assume responsibility for ensuring that the financial interest of the employees of the institution do not compromise the objectivity of the design, conduct, or reporting of such research.

For PHS and NSF grant applications, information on "Significant Financial Interests" that would reasonably appear to be affected by the research is now required to be provided by any investigator responsible for the research design, conduct, or reporting of PHS-funded or NSF-funded research. This information must be provided at the time an application is submitted. Prior to award, the institution must resolve any conflicts in financial interest, i.e., those that are likely to affect the research, or that are in entities with financial interests that could be affected by the research proposed.

The PHS and NSF define "Significant Financial Interest" as anything of monetary value, including, but not limited to salary or other payments for services (e.g., consulting fees or honoraria); equity interests (e.g., stocks, stock options of other ownership interests); and intellectual property rights (e.g., patents, copyrights and royalties from such rights), where such payments exceed $10,000 annually, the equity interest exceeds five percent ownership or a value of $10,000 (whichever is greater) at fair market value, or royalty payments exceeding $10,000 annually.

"Investigator" means the principal investigator and any person at the institution who is responsible for the design, conduct, and reporting of a research project funded by the PHS or NSF, or proposed for such funding. Relating to financial interests, "Investigator" includes the investigator's spouse and dependent children.

Financial interests that would not bias the project are exempt. Exemptions include: (1) salary, royalties, or other remuneration from the institution; (2) income from seminars, lectures, or teaching engagements sponsored by public or nonprofit entities; (3) income from service on advisory committees or review panels for public or nonprofit entities; or (4) financial interest in business enterprises or entities if the value of such interests do not exceed $10,000 or represent more than a five percent ownership interest for any one enterprise or entity when aggregated for the investigator and the investigator's spouse and dependent children.

Assurance is made by all investigators on each PHS and NSF proposal by checking the appropriate box on the Duke University Application Transmittal Form and is verified by the signature of the investigator(s) and by the signature of the Official signing for the applicant organization on the face page of the application.

If a significant financial interest exists, please provide to the Office of Research Support, with the grant application, a confidential disclosure of the nature of the interest in a sealed envelope. The disclosure will be referred to the Vice Provost for Research for review. If further review is required, under the Statement of Conflict of Interest for Duke Faculty, potential conflicts may require referral to the Provost's office and an ad hoc subcommittee of the Research Policy Committee for resolution before an award is made. Resolution will include determining whether or not an actual conflict of interest exists and, if so, what actions must be taken to manage, reduce, or eliminate it.

Questions about potential conflicts of interest may be directed to the Vice Provost for Research at any time.