To whom does the NSF Conflict of Interest (COI) policy apply?
The NSF requires conflict of interest disclosures from all investigators who are defined as “the principal investigator, co-principal investigators/co-project directors, and any other person at the organization who is responsible for the design, conduct, or reporting of research or educational activities funded or proposed for funding by NSF.” The COI screening questions are required to be completed by all persons who certify as a PI or Co-I. Those screening questions are in compliance with NSF requirements for disclosure and the MIT COI policy. Subaward investigators should make their disclosures to the organization that will accept the subaward. If any proposal includes a key person who meets the NSF definition of an investigator, but is not a PI or Co-PI, please contact your RAS Contract Administrator for additional guidance.
What must be reported under the NSF policy?
The NSF requires each investigator disclose to a responsible representative of the organization all significant financial interests of the investigator (including those of the investigator’s spouse and dependent children): (i) that would reasonably appear to be affected by the research or educational activities funded or proposed for funding by NSF; or (ii) in entities whose financial interests would reasonably appear to be affected by such activities. In other words,
"significant financial interest" means anything of monetary value, including, but not limited to, salary or other payments for services (e.g., consulting fees or honoraria); equity interest (e.g., stocks, stock options or other ownership interests); and intellectual property rights (e.g., patents, copyrights and royalties from such rights), but does not include
- salary, royalties or other remuneration from the applicant organization;
- any ownership interests in the organization, if the organization is an applicant under the Small Business Innovation Research Program or Small Business Technology Transfer Program;
- income from seminars, lectures, or teaching engagements sponsored by public or non-profit entities;
- income from service on advisory committees or review panels for public or nonprofit entities;
- an equity interest that, when aggregated for the investigator and the investigator’s spouse and dependent children, meets both of the following tests: does not exceed $10,000 in value as determined through reference to public prices or other reasonable measures of fair market value, and does not represent more than a 5% ownership interest in any single entity; or
- salary, royalties or other payments that, when aggregated for the investigator and the investigator’s spouse and dependent children, are not expected to exceed $10,000 during the prior twelve-month period."
When are disclosures required?
NSF requires that a disclosure be made at the time of proposal and be updated annually, or whenever new reportable interests are obtained. Each disclosure must be reviewed before funds may be spent.
What happens if a potential conflict is disclosed?
All Disclosures are reviewed by a designated institutional representative prior to any spending on the award. If no conflict exists, or if a satisfactory COI Management Plan is put into place prior to any spending, no review or approval outside of MIT is required.
NSF Conflict of Interest Policy: AAG Chapter IV.A