Conflicts of Interest

Georgia State University is fully committed to maintaining objectivity in research and upholding the highest scientific and ethical standards. The Policy on Financial Disclosures in Sponsored Research promotes objectivity in University research by establishing processes that provide a reasonable expectation that the design, conduct, and reporting of sponsored research are free from bias resulting from financial conflicts of interest of the University employee involved in the research. The Policy complies with the Public Health Service revised regulations on the “Responsibility of Applicants for Promoting Objectivity in Research for which PHS Funding is Sought” (see PHS FAQs).

Required Conflicts of Interest Training

All individuals capable of influencing the outcome or results of sponsored projects as determined by the Principal Investigator must complete the CITI Conflicts of Interest training for Georgia state University prior to engaging in activities pursuant to the sponsored project and must be repeated at least every four years.

To access the training, all Investigators should go to CITI and log in or, if a new CITI user, follow the “Register Here” link. Click “Add a course or update your learner groups.” Answer “Yes” to the question “Would you like to take the Conflict of Interest course?” Click “Continue” then “Conflict of Interest” will appear under “My Courses.” Be sure to complete all four modules.

Requirements for Investigators on Sponsored Projects

Prior to proposal submission, all investigators must demonstrate compliance with GSU’s commitment to ensuring objectivity in research by:

  1. Completing the CITI training module within the last four years
  2. Completing a Significant Financial Interest Disclosure form identifying the specific project for which the proposal will be submitted. Each investigators/key personnel identified on the project must complete and submit this form separately.

NOTE: An investigator is any individual, regardless of title or position, who is capable of influencing the outcome or results of the sponsored project.

The Policy on Financial Disclosures in Sponsored Research promotes objectivity in University research by establishing processes that provide a reasonable expectation that the design, conduct, and reporting of sponsored research are free from bias resulting from financial conflicts of interest of the University employee involved in the research. The Disclosure of Significant Financial Interest form below must be completed by every person working on a sponsored project (faculty, staff, and students). The guidance information below will walk you through the online completion of the Disclosure of Significant Financial Interest Form.

Disclosure of Significant Financial Interest Form

(External link)

Disclosure of Significant Financial Interest Form Guidance
Investigator means any individual, regardless of title or position, who is responsible for the design, conduct, performance or reporting of a Sponsored Project. An Investigator may include full-time and part-time faculty; staff; students; consultants; collaborators; and evaluators. For clarification, “responsible for” means that the individual is capable of influencing the outcome or results of the Sponsored Project.

Significant financial interest means a Financial Interest consisting of one or more of the following interests of the Investigator and those of the Investigator’s Immediate Family that reasonably appears to be related to the Investigator’s University Responsibilities:

  1. With regard to any publicly traded entity, any Remuneration received from such entity in the twelve (12) months preceding the disclosure and the value of any Equity Interest in such entity as of the date of disclosure that, when aggregated, exceeds $5,000;
  2. With regard to any non-publicly traded entity:
    1. any Remuneration received from such entity in the twelve (12) months preceding the disclosure that, when aggregated, exceeds $5,000, or
    2. any Equity Interest regardless of value;
  3. intellectual property rights (e.g., patents, copyrights), where income related to such rights and interests has been received;
  4. reimbursed or sponsored travel, excluding travel that is reimbursed or sponsored by a federal, state, or local government agency, an institution of higher education, an academic teaching hospital, a medical center, or a research institute that is affiliated with a institution of higher education.

Significant Financial Interest does not include the following types of Financial Interests: (1) salary, royalties, or other Remuneration paid by the University to the Investigator if the Investigator is currently employed or otherwise appointed by the University, including intellectual property rights assigned to the Georgia State University Research Foundation and agreements to share in royalties related to such rights; (2) income from investment vehicles, such as mutual funds and retirement accounts, as long as the Investigator does not directly control the investment decisions made in these vehicles; (3) income from seminars, lectures, or teaching engagements sponsored by a federal, state, or local government agency, or an institution of higher education, an academic teaching hospital, a medical center, or a research institute that is affiliated with an institution of higher education; or (4) income from service on advisory committees or review panels for a federal, state, or local government agency, or an institution of higher education, an academic teaching hospital, a medical center, or a research institute that is affiliated with an institution of higher education.

Equity interest means any stock, stock option, or other ownership interest, as determined through reference to public prices or other reasonable measures of fair market value.

Financial interest means anything of monetary value, whether or not the value is readily ascertainable.

Immediate family means an Investigator’s spouse and dependents.

Remuneration means any payment for services including, but not limited to, salary, consulting fees, honoraria, and paid authorship.

University responsibilities means an Investigator’s professional responsibilities on behalf of the University including, but not limited to, activities such as research, research consultation, teaching, professional practice, institutional committee memberships, and service on panels.

Additional resources regarding compliance with the Disclosure of Significant Financial Interest can be found in the documents below.

What Sponsored Travel must be reported?
All investigators must report the occurrence of any reimbursed or sponsored travel paid on behalf of the investigator that is related to their institutional responsibilities, regardless of the value. The monetary value does not need to be reported, however the purpose of the trip, sponsor, destination and duration of the trip must be disclosed. This may be disclosed prospectively for the year. For example: “Purpose: Board of Trustees meeting—Sponsor: American Heart Association—Destination: Texas—Duration: 4 trips in 2012 for 2 days each.” Travel sponsored or reimbursed by institutions of higher education, academic medical centers and research institutions affiliated with academic institutions does not need to be disclosed. Travel reimbursed or sponsored by other non-profit organizations must be reported.
Does sponsored travel funded through foreign governments have to be reported?
Yes. If foreign governments are providing the funding for the travel it needs to be disclosed. U.S. government funded travel, including funding from state and local governments does not have to be disclosed. Also, travel funded by institutions of higher education, academic medical centers and research institutions affiliated with academic institutions within the United States does not need to be disclosed.
Will OSPA submit a proposal if the disclosure of significant financial interest form has not been completed?
A proposal for funding from a PHS agency will not be submitted until each investigator has completed a disclosure. The individual departments and colleges/deans should ensure the disclosures are completed before the proposal reaches OSPA.
What if information in my disclosure changes and requires updating?
Those changes must be done by the investigator directly and should be made within 30 days of the change.
If no information has changed from an Investigator’s last submitted disclosure form, does the Investigator have to complete a new disclosure form to submit a proposal? If so, what proposal information do they need to include?
The disclosure must be re-submitted with each new proposal and must be updated with the new proposal-specific information.
What happens if an Investigator fails to submit an updated disclosure form within thirty days of a change (i.e. acquiring a new significant financial interest, discovering a previously undisclosed significant financial interest)?
Changes should be reported as soon as discovered (within 30 days if possible). If changes are not reported within 30 days, GSU may be required to conduct a retrospective review depending on the funding agency (e.g. PHS agencies). If the review determines the research was biased by the failure to timely disclose, GSU may be required to notify the funding agency and provide a mitigation report. Additional action may be taken by the University and the funding agency.
How is the PI held accountable for failure to report changes to their disclosure within 30 days?
Possible sanctions for violation of the Policy by an investigator include administrative intervention, withholding funding or preclusion from participation in government funded programs, or termination of employment.
Do resubmissions or noncompeting continuations require disclosures?
Yes, this Policy applies to each grant or cooperative agreement.

We understand the Georgia State research community may have questions or concerns regarding the Conflict of Interest changes. Below we've created a feedback form to help us communicate with the research community and provide timely responses to your concerns.