CSUSB/UEC Financial Conflict of Interest Policy

California State University, San Bernardino

Conflict of Interest Policy for External Sponsored Programs

CSUSB and the University Enterprises Corporation at CSUSB (UEC) encourage the involvement, collaboration, and partnership of academic researchers and educators with public and private sector grants, contracts, ventures, and entrepreneurial activities. However, such involvements create a risk of conflict between the private interests of individuals, the companies with which they are involved, and the public interest. CSUSB and the UEC have adopted policies that regulate potential conflicts of interest among faculty and staff members employed on grants and contracts as required by federal, state, CSU, and CSUSB laws and policies. If a real or potential conflict is disclosed, it will be confidentially reviewed and a determination made whether the conflict requires the development of a resolution plan to address the conflicts.

Investigators of all externally sponsored programs must follow this policy.
 
View details of the Financial Conflict of Interest (FCOI) disclosure requirements by funding source.

1.     NIH/PHS grants.

Investigators must complete a Conflict of Interest training program (CITI Training Site). Log-on at: CITI Program and complete the CSUSB Federal Disclosure Form prior  to submission of an NIH/PHS grant proposal and upon the receipt and during the administration of the award.  

Additional NIH/PHS FCOI requirements are detailed in the FCOI Disclosure Requirements by Funding Source.

Reference: 
https://grants.nih.gov/grants/policy/coi/index.htm

2.    NSF/USDA grants. 
Investigators must complete the CSUSB Federal Disclosure Form prior to submission of an NSF/USDA grant proposal, when new personnel is added and when investigator’s financial interest changes. 

Additional NSF/USDA FCOI requirements are detailed in FCOI Disclosure Requirements by Funding Source.

References:
https://www.nsf.gov/pubs/manuals/gpm05_131/gpm5.jsp
https://nifa.usda.gov/regulations-and-guidelines

3.    Non-governmental grants.
  
Investigators who are awarded grants from non-governmental sponsors, which are not exempt* from the disclosure requirement must complete the Chancellor’s Office Conflict of Interest training program and complete the Form 700U.

*View the list of exempt non-governmental agencies.
Additional non-governmental FCOI requirements are detailed in FCOI Disclosure Requirements by Funding Source.
    
Reference:
http://www.calstate.edu/HRAdm/pdf2011/Form700-U-10-11-CSU.pdf