Research and Sponsored Projects Manual (RSP)

Effective: 10/1/1995

Revised: 3/1/2009

RSP 206: Objectivity in Research—Disclosure of Financial Interests and Management of Conflicts of Interest

Purpose

To promote objectivity in research and other sponsored project activities by establishing standards to protect the design, conduct, and reporting of externally funded projects from potential bias by an investigator’s conflicting financial interests, all principal investigators (PIs) and co-principal investigators are required to disclose their significant financial interests (as defined in RSP 004, “Definitions”).

Sources

45 Code of Federal Regulations Part 94 §§ 1–6

National Science Foundation Grant Policy Manual, Section 510, Conflict of Interest, as amended by 60 Federal Register 35820

Authority. 42 United States Code 216, 289b-1, 299c-3

National Institutes of Health Grants Policy Guidance, Financial Conflict of Interest: Objectivity in Research, 42 Code of Federal Regulations (CFR) Part 50 Subpart F

Public Health Service Regulation 45 Code of Federal Regulations Part 50 Subpart F

Arizona Revised Statutes § 15–1635 and §§ 38–501 through –511

Arizona Board of Regents Policy Manual - 6-908, 6-909.10

Office of the Vice President for Research and Economic Affairs

Applicability

All employees conducting research at the university with funding from any public or private source outside the university

Policy

Arizona State University has comprehensive and interrelated policies and guidelines that address the conduct of ASU employees, their interactions with private industry, and disclosure of conflict of interest. The policies work together to set high standards for employees, ensure the integrity of ASU research results, and guide interactions of ASU employees in their partnerships with industry and other university-related activities.

University employees are expected to comply with all federal and state laws and university policies related to conflict of interest, including Arizona Revised Statutes §§ 38–501 through –511 and the Academic Affairs Policies and Procedures Manual, ACD 204–08, “Conflict of Interest.”

The National Science Foundation (NSF) and the Public Health Service (PHS), including the National Institutes of Health (NIH), require all investigators to disclose to their universities every significant financial interest that may present a conflict of interest. All disclosures must be made prior to proposal submission to these sponsors and updated, if necessary, prior to the expenditure of any funds upon receipt of an award. The university requires all investigators to file an annual disclosure statement of significant interest.

For more information and forms, see the Office for Research Integrity and Assurance.

Cross-References

For more information about conflict of interest, see:

1. RSP 604, “Intellectual Property Management Implementation Policy”

   and

2. the Academic Affairs Policies and Procedures Manual: ACD 204–08, “Conflict of Interest.”

For more information about conditions of service at ASU, see:

1. the Academic Affairs Policies and Procedures Manual: ACD 504, “Conditions of Administrative Service at ASU”

   and

2. the Staff Personnel Policies and Procedures Manual:
   1. SPP 302,“Conditions of Administrative Service at ASU”
   2. SPP 320, “Conditions of Service Professional Service at ASU”

      and

   3. SPP 813, “Code of Conduct for Business Activities.”

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