Financial Conflicts of Interest Policy
A potential conflict of interest occurs when there is a divergence between an individual's private interests and his or her professional obligations to Nova Southeastern University such that an independent observer might reasonably question whether the professional actions or decisions of an individual is determined or influenced by considerations of personal gain, financial or otherwise. An actual conflict of interest depends on the situation and on the character or actions of the individual. For the purposes of NSU Office of Sponsored Programs Policy (OSP), Financial Conflicts of Interest in Sponsored Programs, a conflict of interest exists when the University, through procedures described herein, reasonably determines that a significant financial interest could affect directly and significantly the design, conduct, or reporting of sponsored projects.
The increasing involvement of academic researchers and educators with industry and private entrepreneurial ventures has raised the potential for conflict of interest. Such real or apparent conflicts, when not appropriately disclosed and addressed, can undermine public and professional confidence in the integrity of University research and sponsored programs.
In accordance with Federal regulations, NSU has a responsibility to manage, reduce, or eliminate any actual or potential conflicts of interest that Investigators may have. OSP Policy, Financial Conflicts of Interest in Sponsored Programs , is intended to meet the federal requirements governing disclosure, management and reporting of financial conflicts of interest (FCOI's). Complying with the policy ensures that potential conflicts are disclosed to the University and that the University manages, reduces, or eliminates FCOI's and reports them to the sponsors so there is a reasonable expectation that the research is unbiased and the public trust is preserved.
University Official
The Vice President for Research is the designated University official for for review of financial disclosures by Investigators and for determining whether any significant financial interest is related to the sponsored program and, if so, whether a financial conflict of interest exists.
Applicability
The policy is applicable to Investigators on sponsored programs funded by, or proposed to, the Public Health Service (NIH, HRSA, CDC, AHRQ, SAMHSA, and others), the National Science Foundation, and any other governmental agency if they have promulgated regulations requiring investigator disclosure of financial interests or institutional policies related to conflicts of interest on sponsored projects.
Each Investigator at NSU to whom the Financial Conflict of Interest in Sponsored Programs (FCOI) applies is responsible for identifying and disclosing his or her significant financial interests/obligations/proprietary interests.
As defined in FCOI Policy, an Investigator is the project director or principal Investigator and any other person, regardless of title or position, who is responsible for the design, conduct, reporting, on a sponsored award, which may include, for example, collaborators or consultants. Spouses, domestic partners, and dependent children are also included for the purposes of disclosure. If a sub-awardee does not have its own policy that complies with University regulations, the organization must follow NSU policies regarding disclosure.
Effective July 2023, NSU implemented Cayuse Outside Interests for managing required disclosures of significant financial and other interests. By using Cayuse Outside Interests in conjunction with the other Cayuse modules, investigators will be able to ensure that their disclosures are complete, up-to-date, and timely, in compliance with the requirements of research sponsors and NSU policy.
Cayuse Outside Interests is different from our prior method, but not in substantive requirements. The disclosure requirements under the FCOI policy and research sponsor terms have not changed. With the Cayuse Outside Interests module, investigators will be asked specific, policy-driven questions to determine whether they have any of the types of financial or foreign interests that require disclosure, and will be able to easily update and track those disclosures electronically in one system. The status of a investigator’s disclosure compliance will be integrated with the Cayuse proposal and award systems, but the details of financial disclosures will remain confidential and access will remain limited to the offices at each campus tasked with managing the FCOI process.
You can access the Cayuse Outside Interest site at: https://nova.app.cayuse.com/
Please reference the step-by-step user guide we have created to assist you in accessing and completing your financial disclosures.
Cayuse Outside Interest User Guide
If you experience any technical issues, please email fcoi@nova.edu with a detailed explanation of the error and provide screen shots whenever possible.
DoR has implemented an Annual Disclosure Campaign, effective July 1, 2023, that will run annually during the month of July every year. Investigators will now be required to complete one financial interest disclosure update in Cayuse each year. PI’s will no longer have to complete separate updates/disclosures for each project and will not have to disclose on behalf of their team but themselves only.
Investigators will receive an automated email from Cayuse when the Annual Disclosure Campaign is open so that they may log into Cayuse to complete it. Investigators will have 30 days to complete their annual disclosure. Please note that investigators will still be required to submit Research-based disclosures for each new proposal submission, as required per federal regulations and NSU policy.
Investigators can reference the step-by-step user guide we have created to assist users in accessing and completing financial disclosures. Cayuse Outside Interest User Guide
It is also important to note that this process is completely separate from the NSU Office of Human Resources (OHR) policy on Conflicts of Interest / Conflict of Commitment Declaration & Disclosure Policy. If an Investigator has disclosed a Conflict of Interest/Commitment through OHR, the same information must also be disclosed through our process.
If you have any questions related to this change, please email FCOI@nova.edu
What is FCOI training?
Office of Sponsored Programs Policy, Financial Conflicts of Interest in Sponsored Programs, is intended to meet federal requirements governing disclosure, management, and reporting of financial conflicts of interest (FCOI’s). The policy requires that Investigators to whom the policy applies (see Section II of the policy) participate in FCOI training prior to engaging in any sponsored program funded by the Public Health Service, the National Science Foundation, or any other governmental agency if the agency has promulgated regulations or policies requiring investigator financial disclosure or requiring institutional conflict of interest policies relating to the award of grants or contracts. Investigators must also complete training at least every four years thereafter, and immediately in certain designated circumstances as outlined in Policy #16.
How do I complete the training?
NSU is using the CITI Program's Conflict of Interest Course to meet the training requirement. To access the training, go to: http://www.citiprogram.org/.
If you do not have a CITI account, you must first create one by clicking “Register Here” from the CITI home page, selecting “Nova Southeastern University” as your participating institution, and completing the registration steps.
If you already have a CITI account:
- Login from the CITI Home Page with your username and password.
- Click on the clink “Add a course or update your learner groups for Nova Southeastern University”.
- Answer “Yes” or “No” to the question “Is this the first time doing the CITI Program as a member of the NSU Community?”
- If you answer “No”, you will be taken to the page where you can select the “Conflict of Interest” Course, which is located at the bottom of the page.
- If you answer “Yes” you will be asked to identify what area of research you are working in. Make sure to select “Conflicts of Interest” so this learner module will appear to you. Then you will be taken to the page where you can select the “Conflict of Interest” Course, located at the bottom of the page.
Federal regulations now require that information about significant financial interests and FCOI's of senior/key personnel on Public Health Service (PHS) funded research projects be made publicly accessible. The University will make such information available, upon written request, if the three requirements below are met:
- The significant financial interest was disclosed and is still held by the senior/key personnel (as defined in Policy)
- The University determines that the significant financial interest is related to the PHS-funded research
- The University determines that the significant financial interests is an FCOI.
To make a request for information, complete the form below and send it to fcoi@nova.edu. A written response will be submitted in five days for requests meeting the above criteria.
Click here for " FCOI Information Request Form"