Research Conflict of Interest

Conflicts of Interest Can Occur in Several Areas

Certain funding agencies have implemented regulations promoting objectivity in research by requiring that a university applying for extramural research funding ensure that there is no reasonable expectation that the design, conduct, and reporting of the research to be funded pursuant to the application will be biased by any significant financial interest of any Investigator working on the research. FGCU’s Financial Conflict of Interest Policy was written to prevent or resolve, through management and/or mitigation, real or apparent conflicts that may exist in relation to research, instruction, and service activities undertaken by University investigators.

Please refer to the Faculty 2021–2024 Collective Bargaining Agreement, the Employee Handbook, and FGCU's regulation on Outside Employment/Activity Regulation for conflicts of interest relating to your employment with the university.

FGCU offers an online Conflict of Interest course through the Collaborative Institutional Training Initiative (CITI). The course includes basic background in the elements of the revised Public Health Service (PHS) federal regulations on financial conflicts of interest and investigator and institutional responsibilities. CITI registration and logon instructions can be found by clicking on the above link.

Policies and regulations regarding conflicts of interest are housed in the Office of the General Counsel.

FGCU Conflicts in Research Related Links

• FGCU Policy on Financial Conflict Of Interest in Sponsored Research
• FGCU Regulation on Outside Employment/Activities
• FAQ’s on Financial Conflict of Interest, Other Support and Foreign Influence
• Financial Conflict of Interest Decision Tree
• Financial Conflict of Interest Disclosure Form

NSF Research Related Link

• NSF Conflict of Interest Regulations, NSF Proposal and Award Policy and Procedures Guide, Chapter IV.A

EPA Research Related Link

• EPA’s Final Financial Assistance Conflict of Interest Policy

PHS Research Related Link

• PHS Conflict of Interest Regulations, 42 CFR Part 50, Subpart F

Other Conflict of Interest Issues Related to the Uniform Guidance

U.S. Department of Education (DOED)

As part of its implementation of 2 CFR 200, DOED adopted 200.318 for procurement under a Federal award, but also established the clause 34 CFR 75.252, Conflict of Interest: Participation in a Project for non-procurement:

75.525   Conflict of interest: Participation in a project.

1. 1. 1. A grantee may not permit a person to participate in an administrative decision regarding a project if:
         1. The decision is likely to benefit that person or a member of his or her immediate family; and
         2. The person:
            1. Is a public official; or
            2. Has a family or business relationship with the grantee.
      2. A grantee may not permit any person participating in the project to use his or her position for a purpose that is—or gives the appearance of being—motivated by a desire for a private financial gain for that person or for others.

If an FGCU employee has a conflict as described by DOED above, prior to submitting the proposal, the Principal Investigator must contact ORSP to discuss how to mitigate or eliminate the conflict.

Useful Links Related to Conflicts of Interest and Ethics

• F.S. 112.313, Standards of conduct for public officers, employees of agencies, and local government attorneys
• State of Florida, Code of Ethics for Public Officers and Employees (F.S. 112.311-112.326)
• Florida Commission on Ethics
• HHS Office of Research Integrity Conflict of Interest Tutorial 

If an FGCU employee has a conflict as described by DOED above, prior to submitting the proposal, the Principal Investigator must contact ORSP to discuss how to mitigate or eliminate the conflict.  For assistance with Federal Financial Conflicts of Interest issues, please contact Donna Gilmore, Director of Research 239-590-7582 or dgilmore@fgcu.edu