Financial Conflict of Interest Agency Regulations

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.

Effective May 20, 2024, the NSF released updated guidance on required disclosures. The guidance document includes the types of activities and financial interests researchers must disclose to the sponsor, where such activities must be reported in the application, when updates are required in the application and award lifecycle, and activities that do not require reporting.

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 document includes the types of activities and financial interests researchers must disclose to the sponsor, where such activities must be reported in the application, when updates are required in the application and award lifecycle, and activities that do not require reporting.

Additional Guidance: Department of Energy

Effective December 20, 2021, the Department of Energy (DOE) issued its issued an Interim Conflict of Interest (COI) Policy for Financial Assistance. The Interim COI policies applies to all Funding Opportunity Announcements (FOAs) issued on or after that date. Researchers may encounter the new requirements at the time of proposal, after an award has been issued, and over the course of a sponsored project. Please read FOAs closely as requirements can vary across award types.

The policy requires that any researcher participating in DOE-sponsored research must submit a financial conflict of interest disclosure and complete financial conflict of interest training. Previously, training and disclosure were required only for researchers who were responsible for the design, conduct, or reporting of the sponsored research.

Additional Federal Regulations