The Public Health Service (PHS), which includes funding agencies such as the National Institutes of Health (NIH) and the Agency for Healthcare Research and Quality (AHRQ), implemented expanded regulations for financial conflict of interest on grants. On August 23, 2012 the State University of New York (SUNY) and the Research Foundation of SUNY (RF) approved a policy which complies with the PHS Financial Conflict of Interest (FCOI) regulations.
Investigator – A SUNY or RF employee who is the project director or principal Investigator and any other person, including a student or post-doctoral fellow, regardless of title or position, who is responsible for the design, conduct, or reporting of research funded by the PHS, or proposed for such funding, which may include, for example, collaborators or consultants.
Institutional Responsibilities – Investigator’s professional responsibilities on behalf of SUNY and/or RF, which may include activities such as research, research consultation, teaching, professional practice, institutional committee memberships, and service on panels such as institutional review boards or data and safety monitoring boards.
Related Party – An investigator’s spouse and dependent children.
Significant Financial Interests (SFI) – A financial interest of the Investigator (or a Related Party) that reasonably appears to be related to the Investigator’s institutional responsibilities and that consists of one or more of the following:
1. With regard to any publicly traded entity, a SFI exists if:
2. With regard to any non-publicly traded entity, a SFI exists if:
3. Intellectual property rights and interests (e.g., patents, copyrights), and royalties from such rights, upon receipt of income related to such rights and interests; or
4. Reimbursed or sponsored travel (i.e., that which is paid on behalf of the Investigator, and not reimbursed to the Investigator so that the exact monetary value may not be known by the Investigator), related to the Investigator’s Institutional Responsibilities, in an amount or estimated amount in excess of $500. Excluded from this requirement is travel that is reimbursed or 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.
Financial Conflict of Interest (FCOI) – A Financial Conflict of Interest exists when a SFI could directly and significantly affect the design, conduct, or reporting of PHS-funded research.
Senior/Key Personnel – Project Director/Principal Investigator and any other person identified as senior/key personnel in the grant application, progress report, or any other report submitted to PHS by SUNY or RF, per PHS regulations.
To comply with the PHS regulations and the SUNY/RF policy, Empire State College commits to the following:
1. The appointment of the Vice Provost of Research, Innovation and Open Education as the Designated Official (DIO). The Vice Provost will review and manage all actual and potential financial conflicts of interests.
2. Responsibilities of the DIO include:
3. Financial Disclosures
Records of all Investigator disclosures of financial interests, DIO’s review of, and response to, such disclosures, and all actions under this PHS FCOI policy, including any retrospective reviews, will be maintained for at least three years from the date of the submission of the final fiscal expenditures report or, if there are special conditions, as specified under 45 CFR clauses.
Public Health Service regulation on Responsibility of Applicants for Promoting Objectivity in Research for which Public Health Service Funding is Sought and Responsible Prospective Contractors.
State University of New York and Research Foundation of SUNY policy titled Policy on the Conflicts of Interest in Public Health Service Sponsored Programs