University of North Carolina at Asheville Investigator Conflict of Interest Policy 1403 (PHS sponsored) or Policy 1404 (non-PHS sponsored) requires that PIs and all personnel working on research projects, regardless of source of funding or lack thereof, disclose financial information that may reasonably be perceived to influence their work. This policy is intended to promote objectivity in research with the reasonable expectation that the design, conduct, and reporting of the research will be free from bias resulting from Investigator financial conflicts of interest.
Please note that having something to disclose does not imply any wrongdoing or inappropriate activities. The emphasis is on disclosure of financial interests so that UNC Asheville can conform to federal financial disclosure rules and those of many granting entities.
Who Needs to Disclose
All University faculty, non-faculty employees, students (graduate and undergraduate, part-time or full-time) and other individuals who, in the course of their association with the University:
- apply for or receive funds for any research or training purpose, by grant or sub-grant, or by contract or subcontract, or by cooperative agreement, or are engaged in research (i.e.: are responsible for the design, conduct, or reporting of research; or (For example: an undergraduate student entering data must disclose because they are engaged in the conduct of the study, or administrative personnel must disclose, who have decision-making authority over the distribution of funds, whether research or discretionary)
- conduct unsponsored/unfunded research
Disclosing for Non-UNC Asheville Researchers
For projects involving contracts, sub-agreements or collaborations with outside institutions or groups, UNC Asheville will take steps to ensure that any sub-recipient Investigator complies with the Public Health Service, pursuant to 42 CFR Part 50, Subpart F by incorporating as part of a written agreement with the sub-recipient terms that establish whether the financial conflicts of interest policy of the awardee Institution or that of the sub-recipient will apply to the sub-recipient’s Investigators.
In the event the outside entity has no investigator conflict-of-interest policy, the written agreement referenced above shall specify time period(s) for the sub-recipient to submit all Investigator disclosures of significant financial interests to UNC Asheville. The sub-recipient will be required to:
- complete the UNC Asheville PHS sponsored Conflict of Interest Disclosure (FCOI) or non-PHS sponsored Conflict of Interest Disclosure.
- provide to the Office of Research and Sponsored Programs before issuance of sub-recipient agreement.
- comply with the UNC Asheville’s Conflict of Interest Policy 1403 (PHS sponsored) or Policy 1404 (non-PHS sponsored).
***The FDP FCOI Institutional Clearinghouse provides a central location for educational institutions and other entities to certify their compliance with PHS Financial Conflict of Interest (FCOI) rules and regulations. Note that not all institutions are registered on this website; you may need to contact them directly for more information about their CoI Program.
What You Need to Disclose
All investigators should disclose any “financial interest” or other personal involvement of the investigator, or his or her immediate family, that relate to the individual’s Institutional responsibilities.
Financial interest means anything of monetary value, whether or not the value is readily ascertainable. Interests include, but are not limited to: income; honoraria or other payment for services; equity such as stock, stock options or other ownership rights, employment; reimbursed travel or sponsored travel; and services, relationships or positions, even if uncompensated.
Excluded from the disclosure requirement are:
- Interests of any amount in publicly traded, diversified mutual funds, pension funds, or other institutional investment funds over which the faculty member does not exercise control); patents and copyrights; contracts, licensing and other agreements; royalties (including those royalties distributed by the University).
- Income from seminars, lectures, or teaching engagements, reimbursed travel or sponsored travel, and service on advisory or review panels sponsored by a federal, state, or local government agency, an Institution of higher education as defined at 20 U.S.C. 1001(a), an academic teaching hospital, a medical center, or a research institute that is affiliated with an Institution of higher education.
For more information on the type of interests to disclose, please review the UNC Asheville’s Policy 1403 (PHS sponsored) or Policy 1404 (non-PHS sponsored) for conflict of interest.