DOE
NSF
PHS

Department of Energy

"This DOE Interim Conflict of Interest Policy for Financial Assistance ("DOE Interim COI Policy" or "Policy") establishes standards that provide a reasonable expectation that the design, conduct, and reporting of projects wholly or in part funded under Department of Energy (DOE) financial assistance awards (e.g., a grant, cooperative agreement, or technology investment agreement) will be free from bias resulting from financial conflicts of interest or organizational conflicts of interest." Effective June 18, 2022, DOE Interim Conflict of Interest Policy.

  • Mandate - The Conflict of Interest Regulations require that AU "have an up-to-date, written, and enforced administrative process to identify and manage conflicts of interest with respect to all projects for which financial assistance funding is sought or received from DOE." (DOE Interim Conflict of Interest Policy, Subpart A).

  • Applicability

    • This DOE Interim COI Policy is applicable to each non-Federal entity that is applying for or that receives a DOE financial assistance award and, through the implementation of this policy by the non-Federal entity, to each Investigator who is planning to participate in or is participating in the project funded wholly or in part under the DOE financial assistance award, and to each non-federal entity sub-recipient under the award." (DOE Interim Conflict of Interest Policy, Appendix I, Section II).

  • Frequently Asked Questions - DOE has issued FAQs for the FCOI regulations. 

  • Continuing Responsibilities - On a timely basis, from the proposal stage throughout the duration of a project subject to the Conflict of Interest regulations, Principal Investigators are responsible for:

    • Identifying Investigators on a proposal, award, and modification to the scope of work, and

    • Ensuring Investigators take DOE Conflict of Interest Training and submit a COI Disclosure. 

  • Who is an Investigator? "Investigator means the Principal Investigator (PI) and any other person, regardless of title or position, who is responsible for the purpose, design, conduct, or reporting of a project funded by DOE or proposed for funding by DOE. DOE program offices have the discretion to expand the definition to include also any person who participates in the purpose, design, conduct, or reporting of a project funded by DOE or proposed for funding by DOE. Such expansion will be specified in the applicable funding opportunity announcement and/or terms and conditions of the financial assistance award." (DOE Interim Conflict of Interest Policy, Appendix I, Section III).

    • The term "investigator" may include collaborators, consultants, or graduate (Master’s or PhD) students where individuals holding those positions otherwise meet the definition of investigator.

    • A project’s "purpose" has its common meaning -- the reason for which a project is proposed or carried out. That reason may include, for example, the desire to improve a technology or solve a specific energy-related problem. Individuals responsible for the "purpose" of a project may not be the same individuals responsible for the "design, conduct and reporting", but their financial interests could still bias the project because the purpose can underpin the whole reason for proposing the project. (U.S. Department of Energy, FAQ Interim COI Policy, No.

  • Before Proposal Submission - Each Investigator planning to participate in research subject to the Conflict of Interest regulations and each Investigator identified by the PI on a particular proposal submission subject to the Conflict of Interest regulations is required to:

    • Complete DOE Conflict of Interest training, and

    • Submit a COI Disclosure including the Investigator's Significant Financial Interests and those of their Immediate Family. 

  • Disclosure after Proposal Submission 

    • Newly Added Investigator - If the PI identifies any Investigators who did not submit a COI Disclosure prior to proposal submission, they must submit a COI Disclosure before engaging in research. 

    • Recertification/Revision of Prior Disclosure - Each Investigator is required to recertify/revise their COI Disclosure at certain points during the reporting year:

      • Within thirty (30) days of discovering or acquiring a new Significant Financial Interest for themselves or their Immediate Family.

    • Annual Disclosure - Investigators are required to submit a COI Disclosure annually.

  • Training after Proposal Submission 

    • Newly Added Investigator - If the PI identifies any Investigators who did not complete DOE Conflict of Interest training prior to proposal submission, they must complete the DOE Conflict of Interest training before engaging in research. 

    • Expiration of Training - Each Investigator is required to complete DOE Conflict of Interest training at least every four (4) years.

    • In Other Circumstances - An Investigator must complete DOE Conflict of Interest training immediately when any of the following apply:

      • The University revises its Financial Conflict of Interest Policy or Procedures in any manner that affects the requirements of Investigators, or

      • An Investigator is newly appointed at the University; or

      • The University finds that an Investigator is not in compliance with the University’s FCOI Policy, Procedures, or Management Plan. ​​

All annual disclosures must now be submitted online through the Endeavor platform.​

  • Endeavor Users

    • Accessing Endeavor: Using Auburn credentials, log in to Endeavor, and navigate to the COI tab.

    • Helpful Guide:  Resources, Videos, and FAQs are available to help you access your Endeavor account, log in, and complete your Disclosure Profile. 

    • Even if you have no revisions, you must re-certify your Disclosure Profile.

    • Auburn Students: Please contact endvcoi@auburn.edu if you need to submit a disclosure.

    • External individuals: Please contact endvcoi@auburn.edu if you need to submit a disclosure.

  • Follow the instructions for CITI SSO and complete the AU Basic RCR Training for ALL Faculty, Staff, Postdocs, and Students  

National Science Foundation

Regulatory Requirements. "NSF encourages the increased involvement of academic researchers and educators with industry and private entrepreneurial ventures, but recognizes that such interactions carry with them an increased risk of conflicts of interest." To address this risk, the NSF Award and Administration Guide contains NSF's conflict of interest requirements for grantee organizations. NSF Award and Administration Guide, Chapter IX(A) - Grantee Standards, Conflict of Interest Policies (NSF 20-1, June 1, 2020).

  • Mandate. NSF requires "that all conflicts of interest for each award be managed, reduced or eliminated prior to the expenditure of the award funds." (AAG  IX.A.1)

  • Applicability: Research or Educational Activities Funded or Proposed for Funding by NSF. NSF establishes standards to be followed by "each grantee organization...to maintain an appropriate written and enforced policy on conflict of interest..." that requires disclosure of significant financial interests by "investigators...responsible for the design, conduct, or reporting of research or educational activities funded or proposed for funding by NSF." (AAG  IX.A.1-2)

Auburn University NSF FCOI Procedures. AU has adopted and maintains NSF FCOI Procedures.  

  • In order for investigators at Auburn University to ensure that no unresolved conflict exists between their outside financial interests and their commitment to their research or educational activities funded by the National Science Foundation (NSF) and/or their proposed protocol for the use of human subjects in research, each "Investigator" must disclose their Significant Financial Interests and those of their immediate family:

    1. that would reasonably appear to be affected by the research or educational activities funded or proposed for funding by NSF; or

    2. in entities whose financial interests would reasonably appear to be affected by such activities

  • Continuing Responsibilities. On a timely basis, from the proposal stage throughout the duration of a project subject to the NSF FCOI requirements, Principal Investigators are responsible for: 

    1. Identifying "Investigators" on a proposal, award, and modification to the scope of work, and

    2. Ensuring "Investigators" submit COI Disclosure Questionnaires.

  • Identifying "Investigators."  "The term 'Investigator' means the principal investigator, co-principal investigators/co-project directors, and any other person identified on the proposed project who is responsible for the design, conduct, or reporting of research or educational activities funded or proposed for funding by NSF."  (NSF Award and Administration Guide, IX.A.). Please consult Guide to Identifying "Investigators" Subject to NSF COI Regulations.

    • The PI, Co-PI, PD, and Co-PD named in the proposal for funding, the award, a progress report, an award modification, or in a subaward, subgrant, or subcontract are always considered an Investigator.

Submitting Disclosure Forms. 

  • All NSF "Investigators" must complete a COI Disclosure at least on an annual basis.

  • Each "Investigator" is required to update their Disclosure Form at certain points during the reporting year:

    • Before the processing of a new proposal, if the participation in the new proposal could create a conflict not previously reported, and

    • Within thirty (30) days of discovering or acquiring a new Significant Financial Interest for themselves or their Immediate Family, and

    • Upon request by the Authorized Institutional Official, as needed to ensure compliance with the AU FCOI policy.

  • Multiple Research Sponsors.  If you have multiple funding sponsors, you do not need to submit multiple disclosure questionnaires at the same time and/or for the same purpose.

    • If you are both a PHS and NSF Investigator, you must submit only one annual disclosure questionnaire.  Depending on the requirements of your multiple funding sources and/or AU policy, you may need to revise your disclosure during the year.

    • For example, if you are a PHS Investigator and have submitted an annual disclosure questionnaire, you do not need to submit a new questionnaire upon submitting a proposal to NSF or upon receiving an award from NSF or a private sponsor unless the specific circumstances may create a COI not previously disclosed.

How to Disclose: All annual disclosures must now be submitted online through the Endeavor platform.​

  • New Endeavor Users

    • Accessing Endeavor: Using Auburn credentials, log in to Endeavor, and navigate to the COI tab.

    • Helpful Guide: Resources, Videos, and FAQs are available to help you access your Endeavor account, log in, and complete your Disclosure Profile. 

    • Even if you have no revisions, you must re-certify your Disclosure Profile.

    • Auburn Students: Please contact endvcoi@auburn.edu if you need to submit a disclosure.

    • External Individuals: Please contact endvcoi@auburn.edu if you need to submit a disclosure.

Completing FCOI Training.  

  • NSF does not require FCOI training. Voluntary Conflict of Interest training is available to all researchers and strongly encouraged by the University.

  • See our CITI Single Sign-On page for more information about accessing CITI Program FCOI Training. 

Public Health Service

Regulatory Requirements. "To address the increasing complexities of the financial interests held by biomedical and behavioral researchers and the resulting interactions among Government, research Institutions, and the private sector, the Public Health Service (PHS) and the Office of the Secretary of the U.S. Department of Health and Human Services (HHS) published revised regulations on the Responsibility of Applicants for Promoting Objectivity in Research for which PHS Funding is Sought and Responsible Prospective Contractors (commonly known as the Financial Conflict of Interest (FCOI) regulations)," effective August 24, 2012.  (NIH FAQs, Introduction)

  • Mandate. The FCOI Regulations require that AU take "action to [manage, i.e.] address [all] financial conflict[s] of interest, which can include reducing or eliminating the financial conflict of interest, to ensure, to the extent possible, that the design, conduct, and reporting of research will be free from bias."  (42 C.F.R. §50.603)

  • Applicability.

    • PHS Research Funded or Proposed for Funding. The FCOI regulations establish standards to be followed by each institution "that is applying for, or that receives PHS research funding by means of a grant or cooperative agreement and [that apply] to each Investigator who is planning to participate in, or is participating in, such research." PHS "Research" includes any activity "for which research funding is available from a PHS Awarding Component through a grant or cooperative agreement... such as a research grant, career development award, center grant, individual fellowship award, infrastructure award, institutional training grant, program project, or research resources award." (42 C.F.R. §§50.602-50.603)

      • Exemptions. Phase I Small Business Innovation Research (SBIR) Program and Phase I Small Business Technology Transfer (STTR) Program applications are exempt from the PHS FCOI Regulations. (42 C.F.R. §§50.602-50.603)

    • Plus Other Sponsor Funding. Various non-governmental foundations and entities have adopted the PHS FCOI Regulations and/or used the PHS FCOI Regulations in their award terms.

  • Frequently Asked Questions. NIH has issued FAQs for the FCOI regulations.  

PI Training and Disclosure Oversight Responsibilities.

  • Continuing Responsibilities. On a timely basis, from the proposal stage throughout the duration of a project subject to the FCOI regulations, Principal Investigators are responsible for:

    1. Identifying Investigators on a proposal, award and modification to the scope of work, and

    2. Ensuring Investigators take FCOI Training and submit FCOI Disclosure Questionnaires. 

  • Who is an Investigator? Consult the Guide to Identifying Investigators Subject to the FCOI Regulations to determine which persons on a project are Investigators.

    • The PI, Co-PI, PD, Co-PD and Senior/Key Personnel named in the proposal for funding, the award, a progress report or an award modification or in a subaward, subgrant, subcontract are always considered an Investigator.

When to Train and Disclose.

  • Before Proposal Submission. Each Investigator planning to participate in research subject to the FCOI regulations and each Investigator identified by the PI on a particular proposal submission subject to the FCOI regulations is required to:

    1. Complete FCOI Training, and

    2. Submit a FCOI Disclosure Questionnaire including the Investigator's Significant Financial Interests and those of their Immediate Family. 

  • Disclosure after Proposal Submission. 

    1. Newly Added Investigator. If the PI identifies any Investigators who did not submit a Disclosure Questionnaire prior to proposal submission, they must submit a Disclosure Questionnaire before engaging in research. 

    2. Recertification/Revision of Prior Disclosure. Each Investigator is required to recertify/revise their Disclosure Questionnaire at certain points during the reporting year:

      • Within thirty (30) days of discovering or acquiring a new Significant Financial Interest for themselves or their Immediate Family.

    3. Annual Disclosure. Investigators are required to submit a Disclosure Questionnaire annually.

  • Training after Proposal Submission. 

    1. Newly Added Investigator. If the PI identifies any Investigators who did not complete FCOI Training prior to proposal submission, they must complete the FCOI Training before engaging in research. 

    2. Expiration of Training. Each Investigator is required to complete FCOI Training at least every four (4) years.

    3. In Other Circumstances. An Investigator must complete FCOI Training immediately when any of the following apply:

      • The University revises its PHS Financial Conflict of Interest Policy or Procedures in any manner that affects the requirements of Investigators, or

      • An Investigator is newly appointed at the University; or

      • The University finds that an Investigator is not in compliance with the University’s FCOI Policy, Procedures or a Management Plan. ​​

How to Disclose: Starting January 2024, Auburn University introduced a new electronic research administration and compliance system. All annual disclosures must now be submitted online through the Endeavor platform.​

  • New Endeavor Users

    • Accessing Endeavor: Using Auburn credentials, log in to Endeavor, and navigate to the COI tab.

    • Helpful Guide: Resources, Videos, and FAQs are available to help you access your Endeavor account, log in, and complete your Disclosure Profile. 

    • Even if you have no revisions, you must re-certify your Disclosure Profile.

    • Auburn Students: Please contact coiadmin@auburn.edu if you need to submit a disclosure.

    • External individuals: Please contact coiadmin@auburn.edu if you need to submit a disclosure.

  • Follow the instructions for CITI SSO and complete the AU Basic RCR Training for ALL Faculty, Staff, Postdocs, and Students