Conflict of Interest

Conflict of Interest

Conflict of Interest

Rowan University recognizes and has addressed the need to establish safeguards to prevent employees, collaborators, subcontractors, subrecipients, and visiting scientists from using their positions for purposes that are, or give the appearance of, being motivated by a desire for financial gain or other personal interest. Significant financial and personal interests are not limited to salaries and payments. It can also include any interest held by the investigator, and his/her immediate family, in a business entity (company, corporation, or other enterprise) whose financial interest might reasonably appear to be affected by such activities. It can also include conflicts of commitment or foreign entities and/or governments support, either non-financial or financial, where there is an obligation by the researcher to commit time and effort to another entity or the researcher is sharing information inappropriately or in a manner that allows the research data and information to be captured and taken by a foreign entity or government. Avoiding conflicts, or perception of conflicts, ensures public trust in Rowan's use of public funds and scientific integrity.

 

CHIPS & Science Act of 2022 and National Security Presidential Memorandum - 33

The CHIPS & Science Act of 2022 was passed into law and one aim of the act was to invest in research and development, science, and technology. Other aims of the act included strengthening US manufacturing, supply chains, workforce development, and national security. The National Security Presidential Memorandum - 33 (NSPM-33) strengthened protections of United States supported research and development (R&D) against foreign government exploitation and interference.

Because R&D in the United States is shared broadly to spur innovation, contribute to the public body of knowledge, and collaborate on creating and developing new technologies, institutions must implement policies and procedures that ensure research supported by U.S. federal government departments, agencies, or offices is not exploited nor shared inappropriately that may result in the U.S. or U.S. institutions losing a technological advantage, loss of economic value or harm to the U.S. economy, or detrimental to U.S. security.

Researchers are the first line of Rowan University to ensure that R&D funded by U.S. federal departments, agencies, and offices adhere to research security and ensure U.S. government investment in R&D supports, strengthens, and improves the U.S. and U.S. institutions economic and national security initiatives.

Researchers must be honest and fully disclose Significant Financial Interests (SFIs), Conflicts of Interest and Conflicts of Commitments, and Other Support received by foreign governments and entities when proposing and submitting R&D projects funded by U.S. federal government departments, agencies, and offices. Proper and full disclosure will allow review, evaluation, and implementation of management action plans, if necessary, to mitigate or eliminate risk so that proposed and awarded R&D projects can be conducted in a manner that establishes compliance with research security.

National Science Foundation (NSF) information about research security training can be reviewed by clicking on the following link: Research Security at the National Science Foundation

National Science Foundation (NSF) has interactive, online modules researchers and administrators can take to enhance and strengthen their knowledge related to research security. You can find the training modules and other information about research security by clicking on the following link: NSF Research Security Training Modules.

 

Conflict of Interest Policies:

Rowan DUR - Managing Conflicts of Interest Policy

Rowan HR - NJ State Ethics Code and Outside Activity Questionnaire

RowanSOM - Industry Relations with Physicians Policy

 

Rowan University School, College, Center or Department/Division Policies

Rowan DUR Managing Conflicts of Interest Policy is not a substitute for any institutional or Rowan School, College, Center or Department/Division policies. Conflicts reported to any Rowan School, College, Center or Department/Division should be reported on the Conflict of Interest (COI) and Significant Financial Interest (SFI) Disclosure Form if it is either a) is a conflict in the proposed research or b) meets the definitions for reporting Significant Financial Interests (SFIs) as required by federal sponsors. 

 

Requirements for Principal Investigators, Co-Principal Investigators and other Key Personnel

Prior to award/release of funds by OSP, investigators should complete CITI training and submit a Conflict of Interest (COI) and Significant Financial Interest (SFI) Disclosure Form.

Proposals, whose sponsor is Department of Health and Human Services (DHHS) department or any agency of DHHS (see list of examples below), National Science Foundation (NSF), and National Aeronautics and Space Administrion (NASA) must complete CITI training and submit the disclosure form to Office of Research Compliance (ORC) prior to release of funds to ensure compliance with federal regulations.

  • Complete CITI Conflicts of Interest Training (Instructions here)
  • Complete and submit Conflict of Interest (COI) and Significant Financial Interest (SFI) Disclosure Form (Found here)
Examples of Public Health Services Operating Agencies:
  • Administration for Children and Families (ACF)
  • Administration on Children, Youth and Families (ACYF)
  • Agency for Healthcare Research and Quality (AHRQ)
  • Centers for Disease Control and Prevention (CDC)
  • Centers for Medicare & Medicaid Services (CMMS)
  • Food and Drug Administration (FDA)
  • Health Resources and Services Administration (HRSA)
  • National Institutes of Health (NIH)
  • National Cancer Institute (NCI)
  • Substance Abuse and Mental Health Services Administration (SAMHSA)

Conflicts of Interest

Known conflicts of interest related to any sponsored research, regardless of funding source, can be reported using the COI/SFI form. When reporting a conflict of interest, you can use the Significant Financial Interest (SFI) section on the COI/SFI form to describe the conflict of interest if it is a financial conflict of interest.

Other Support

Other support, either financial or non-financial assistance and support, provided by foreign, non-U.S. governments, entities, corporations, institutions, or individuals must be reported to Rowan Office of Research Compliance Conflict of Interest administration. You can use the COI/SFI form to report other support.

Please click here to download and complete the Conflict of Interest (COI) and Significant Financial Interest (SFI) Disclosure Form and submit to the Office of Research Compliance and Office of Sponsored Programs for reporting any SFI, COI, or other support.

Public Disclosure Requests

Pertaining to the DHHS revised regulations, the public can request information about conflict of interests related to DHHS / PHS agency funding. Rowan University abides by the regulation, and please click on the link below to review Rowan University's public statement and how to obtain information related to financial conflict of interests.


Public Disclosure Statement