The regulatory landscape for financial conflicts of interest in research shifts frequently based on federal sponsoring agencies. Our team monitors these changes and shares updates with the UO research community.
Additional Guidance: National Science Foundation
- Effective May 20, 2024, the NSF released an updated Proposal and Award Policies and Procedures Guide.
- Specifically, see NSF's Conflict of Interest Policy
- Effective May 20, 2024, the NSF released updated guidance on required disclosures.
- The guidance includes the types of activities and financial interests researchers must disclose to the sponsor, where the disclosure should be made (i.e., biographical sketch; current/pending support document; or facilities, equipment, and other resources), when updates are required in the application and award lifecycle, and activities that do not require reporting.
- Please see the UO guide for guidance on making disclosures in a biographical sketch and current/pending support document.
- Effective January 30, 2023, the National Science Foundation (NSF) is amending its definition of “significant financial interest” to include “venture or other capital financing.” As a result, faculty with NSF funding who also have equity and/or an ownership interest in a non-publicly traded company may be required to disclose additional information about the investors in the non-publicly traded company, activity, or interest.
Additional Guidance: National Institutes of Health
- Effective June 8, 2022, the NIH released updated guidance on required disclosures.
- The guidance includes the types of activities and financial interests researchers must disclose to the sponsor, where the disclosure should be made (i.e., biographical sketch; current/pending support document; or facilities, equipment, and other resources), when updates are required in the application and award lifecycle, and activities that do not require reporting.
- Please see the UO guide for guidance on making disclosures in a biographical sketch and current/pending support document.
- NIH's Financial Conflict of Interest Policy enacts 42 C.F.R. Part 50, Subpart F: Responsibility of Applicants for Promoting Objectivity in Research for which Public Health Service Funding is Sought and 45 C.F.R. Part 94: Responsible Prospective Contractors
Additional Guidance: Department of Energy
- Effective August 2026, the Department of Energy (DOE) issued a final rule for its Conflict of Interest Policy for Financial Assistance, under 2 CFR Part 200 Subpart C. There are important differences in the DOE COI Policy from other agencies:
- Researchers must update their conflict of interest disclosures in the Research Administration Portal within 15 days of acquiring a new Significant Financial Interest or a change in an existing one.
- Researchers must disclose in the Research Administration Portal reimbursed or sponsored travel of any amount unless the travel is funded by a local, state, or federal agency; by a U.S. institution of higher education; an academic teaching hospital; or a research institute affiliated with a U.S. institution of higher education.
- Researchers must disclose in their current/pending (other) support document gifts provided without terms and conditions if that gift supports or relates to their professional research (including basic and fundamental research), development, demonstration, and/or deployment efforts.
- The UO must manage apparent conflicts of interest for DOE researchers. An apparent conflict occurs when a conflict may appear to exist to a reasonable outside observer even if there is no actual or potential conflicts.
- Researchers must complete conflict of interest training every two years, and the DOE will accept research security training that addresses conflicts of interest and commitment. UO researchers already complete research security training annually, which serves as a refresher course to meet the DOE requirements. Researchers must still complete required financial conflict of interest in research training every three years under the UO’s Financial Conflict of Interest in Research Policy.
- The UO must review each researcher’s Significant Financial Interests disclosed in the Research Administration Portal against the sponsored project at the time of proposal. Conflicts that the UO cannot manage or any conflict with a foreign entity must be disclosed in the proposal itself.
- Subawardees on DOE projects must have an enforced conflict of interest and conflict of commitment policy or they must use UO’s Financial Conflict of Interest in Research Policy and the conflict of commitment requirements of the UO’s Conflict of Interest, Conflict of Commitment, and Outside Activities Policy.