Conflicts of Interest
Conflicts of interest (COI) involve circumstances where an individual's professional actions or decisions at the university could be influenced by considerations of personal gain, usually of a financial nature, as a result of interests outside his/her university responsibilities. The central theme in addressing COI is transparency, and the first step is disclosure of the interest through the Conflicts of Interest and Commitment (COIC) disclosure in AccessPlus.
All ISU personnel must comply with ISU's Conflicts of Interest and Commitment Policy, and all faculty and P&S staff are required to complete an annual COIC Disclosure in AccessPlus. In addition, investigators who receive funding from, apply for funding from, or have their salary funded by a grant from any U.S. Public Health Service agency, must also comply with stricter PHS Financial Conflict of Interest Regulations.
Instructions for All ISU Investigators
Faculty and P&S personnel must disclose Conflicts of Interest and Commitment electronically via AccessPlus at the beginning of employment and thereafter at least once per year, generally in the month of January, and whenever the employee's situation changes.
Instructions for PHS Investigators
Before Proposal Submission: Under PHS Regulations, you must submit a COIC Disclosure prior to proposal submission. If you fail to comply with the disclosure requirements, you will be prevented from applying for PHS funds.
Prior to submitting a proposal to PHS on or after August 24, 2012, you must have completed the COIC Disclosure Standard Form in AccessPlus within the last 12 months, answering 'Yes' to Question 2.
If, after completing the PHS COI Disclosure, you are reimbursed for travel or have travel paid on your behalf by an entity that engages in activities that could reasonably be perceived by non-experts as being related to your university responsibilities, you must disclose the travel within 30 days of the end of the trip via a PHS Travel Disclosure.
- The travel disclosure requirement applies to all entities sponsoring travel other than Iowa State University; a grant or contract to Iowa State University; a U.S. federal, state, or government agency; other U.S. institution of higher education; an academic teaching hospital; a medical center; or a research institute that is affiliated with a U.S. institution of higher education.
Before Expenditure of Funds: PHS Regulations require disclosure, training, and management of Financial Conflicts of Interest before you can expend funds on a PHS project. ISU will not set up a PHS Award until you have met these requirements.
Prior to engaging in PHS-funded research with a Notice of Award date or noncompeting continuation segment beginning on or after August 24, 2012 you must:
- Have an up-to-date COIC Disclosure Standard Form in AccessPlus to which you have answered 'Yes' to Question 2;
- Complete online COI training through Collaborative Institutional Training Initiative (CITI); and
- Have a COI Management Plan in place with the COI office, if required.
Forms for PHS Investigators at ISU
- List of Agencies within the Public Health Service
- Guidance to Amended FCOI Regulations (PHS)-Memo of January 3, 2012
- PHS Disclosure and Training Requirements-Memo of June 15, 2012
- NIH Financial Conflict of Interest FAQs