Report Conflict of Interest

Per federal regulations, SF State requires that Principal Investigators (PIs), Co-PIs, Subcontractors/Subrecipients, Consultants, and any others with significant program-based responsibilities on a sponsored project disclose significant financial interests (and those of their spouse and dependent children) that could be reasonably expected to bias the design, conduct, or reporting of the project.

All PIs, Co-PIs, Subcontractors/Subrecipients, Consultants, & others with significant responsibilities listed on a proposal for external funding must complete either the California Form 700-U or the Disclosure of Financial Interests Certification Form (depending upon the source of funds) before expenses can be charged to a project.

Additional Guidelines for Faculty Owned or Controlled Entities

NIH & Other PHS funded Projects - New Conflict of Interest Regulations

Submit your  NIH/PHS Proof of COI Training to ORSP here

New federal regulations (PDF, 336KB) regarding financial conflicts of interest were issued by the Department of Health and Human Services in September of 2011, and went into effect August 24, 2012. These new regulations specifically impact PIs, Co-PIs and key personnel receiving funds from Public Health Service (PHS) agencies (see below for a list of agencies impacted by the revised regulations). ORSP has updated its Financial Conflict of Interest Policy and Procedure, as well as its Disclosure of Financial Interests Certification form, accordingly. Additionally, as of fall 2012 it will implement a new training program for PIs who are awarded PHS sponsored projects.

PHS agencies impacted by the revised regulations:

  • Agency for Healthcare Research and Quality (AHRQ)
  • Agency for Toxic Substances and Disease Registry (ATSDR)
  • Centers for Disease Control and Prevention (CDC)
  • Food and Drug Administration (FDA)
  • Health Resources and Services Administration (HRSA)
  • Indian Health Service (IHS)
  • National Institutes of Health (NIH)
  • Substance Abuse and Mental Health Services Administration (SAMHSA)

The most significant changes pertaining to PHS-funded projects:

  • The disclosure threshold for a Significant Financial Interest on PHS funded projects has been lowered to $5,000
  • Extent of Investigators’ disclosure of information regarding their Significant Financial Interests
  • Institutional management of identified Financial Conflicts of Interest (refer to SFSU Financial Conflict of Interest Policy for details)
  • Information reported to the PHS funding component and made accessible to the public
  • Requires Investigator to have Conflict of Interest Training
  • Disclosure of reimbursed or sponsored travel related to a PI’s Institutional responsibilities, not including travel reimbursed or sponsored by a federal, state, or local government agency, an institution of higher education, academic teaching hospital, medical center, or research institute affiliated with an Institution of higher education

What are the most significant changes?

How, exactly, does this apply to “travel”?

For more information, please contact ORSP's AVP, Michael Scott ( or 415-405-3943)

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