Conflict of Interest (COI) Responsibilities

Responsibilities

Employees

Every USU employee involved in research (or submitting proposals) is required to complete the Conflict of Interest for Researchers training in the Learn Blue system and complete a COI disclosure via Kuali. The COI training is included as part of the university-wide annual compliance training schedule.

A new disclosure is required:

• When an employee is first hired at USU
• Within 10 days of a change to the employee’s Significant Financial Interest(s)
• Upon being awarded a sponsored project if a financial entity has been previously disclosed

AND

• Within 365 days of the most recent disclosure submission

**Please note that failure to comply with COI policies may subject offenders to potential sanctions, ranging from a verbal warning to termination of employment.

RIC

RIC is responsible for collecting, tracking, and maintaining all records associated with Conflicts of Interest related to research at USU.

RIC reviews every researcher COI disclosure, determines if a research-related COI exists, and makes the final approval decision for all research Management Plans.

RIC provides education to faculty, students, and staff and assists other USU offices and committees (including the IRB, SPO, and IACUC) with questions concerning research COIs.

Disclosing Foreign Support, Interests, Collaboration

Utah State University deeply values our international research collaborations and the contributions of our students and scholars from around the world. These global partnerships enrich our culture and are critical to advancing our research endeavors.

Several federal agencies have issued information and guidance concerning undue foreign influence on federally funded research. In particular, agency communications have centered around the following issues:

• Disclosure of research support
• Disclosure of foreign appointments
• Diversion of intellectual property
• Sharing of confidential information by application peer reviewers
• Participation in foreign talent recruitment programs

DISCLOSE foreign appointments, research support, and financial interests, including travel, in the USU Kuali COI module, as required by the USU’s Conflict of Interest Policy #2301 and federal agencies.

REPORT all research support, including foreign support, in accordance with sponsor requirements at the proposal stage, and in progress reports.

• Any payment, research support (e.g. lab supplies, support of students), reimbursement, travel support or other compensation, of any amount, that you have received or will receive, from a foreign entity must be disclosed as an Other Support and Appointments in your COI disclosure.

DISCLOSE other professional activities, including affiliations.

FOLLOW the sponsor’s prior approval requirements for a foreign collaboration/component, and engage the Sponsored Programs Office for assistance. Additional agency specific information can be found in the Agency-Specific Information on Disclosing Foreign Support section.

Supporting Documentation for Foreign Activities (National Science Foundation)

The National Science Foundation has issued new requirements—outlined in NSF Important Notice 149 —regarding supporting documentation for foreign activities disclosed by senior/key personnel on NSF proposals and awards.

Required documentation includes:

• Foreign appointments (paid or unpaid)
• Employment agreements with international entities
• Consulting or contractual arrangements with foreign organizations
• Contracts or grants with foreign institutions
• Participation in foreign talent recruitment programs
• Any documents supporting items disclosed in Current and Pending (Other) Support

Institutions must review these materials to ensure they align with NSF’s disclosure and award compliance requirements, retain them, and make them available to NSF upon request.

USU will collect this documentation through the COI disclosure. If you disclose any foreign activities—or if any foreign activities appear in your Current and Pending (Other) Support—please attach the corresponding documentation directly in your COI disclosure. Documents may be uploaded within the entity information pop‑up or at the end of the disclosure form. Reminders will be incorporated into the COI disclosure to prompt faculty to provide the needed documentation.

What Counts as Foreign Activity Documentation?

Documentation may include PDFs, scans, emails, screenshots, or official correspondence that verify the activity. Examples of possible documentation include: