Researcher-Specific Disclosure and Management Requirements

Conflicts Of Interest For Researchers

Purpose

Research conflicts of interest (COIs) may arise from financial interests, professional or personal relationships, intellectual property, industry partnerships, institutional roles, or outside activities that intersect with the conduct of research. If not appropriately disclosed and managed, such interests may compromise, or appear to compromise, research objectivity, integrity, participant protections, academic decision-making, or public trust.

The purpose of this procedure is to implement University Policy 2301: Individual Conflicts of Interest for Researchers by describing:

what outside interests and relationships must be disclosed;
when disclosures are required;
how disclosed information is assessed for potential Researcher‑related COI or conflicts of commitment (COC);
how identified conflicts are managed through appropriate safeguards; and
circumstances where RIC may determine a conflict is unmanageable.

This procedure is intended to support transparency, protect the integrity of research and other institutional responsibilities, safeguard students and research participants, and ensure compliance with applicable sponsor and regulatory requirements.

Procedures

COI Program Administration

The Vice President for Research (VPR) is responsible for oversight of the University’s research COI program and has designated the Research Integrity and Compliance (RIC) office to administer the program.

RIC is responsible for:

collecting and reviewing Researcher disclosures;
identifying actual, potential, or perceived COIs and COCs related to research or institutional responsibilities;
developing and overseeing conflict management measures when needed; and
ensuring compliance with applicable University policies, sponsor requirements, and regulations.

This procedure applies to all Researchers as defined in Policy 2301.

Certain sponsors impose additional COI requirements. USU is responsible for reviewing disclosures, implementing management plans when required, and reporting conflicts to sponsors when mandated. Researchers are not responsible for submitting sponsor reports directly but are responsible for providing complete and timely disclosures and complying with approved COI management plans.

Identifying Researchers

A Researcher is, as defined in University Policies 2301 and 4100, any person affiliated with USU whose role statement, job description, employment assignment, area of study, or function within the University, either in whole or in part, includes research, creative endeavors, scholarly activity, or other activities overseen by the Office of Research, regardless of discipline or funding source.

This includes faculty, professional research staff, research assistants, laboratory and clinical personnel, and others as may be designated by the Vice President for Research. Individuals engaged in extension activities, creative or artistic scholarship, applied research, community‑engaged scholarship, instructional or pedagogical research, or other non‑traditional research activities are included when those activities fall under the oversight of the Office of Research.

An individual may be considered Researchers if they:

have research, creative, scholarly, or other Office‑of‑Research‑overseen component in their role, appointment, or responsibilities;
serve as a Principal Investigator (PI), Co‑Principal Investigator (Co‑PI), Key Personnel, or other investigator on a sponsored project proposal or award;
serve as an investigator on an active protocol reviewed by the Institutional Review Board (IRB), Institutional Biosafety Committee (IBC), or Institutional Animal Care and Use Committee (IACUC); or
are designated as a Researcher by an appropriate University officials, consistent with University policies and institutional responsibilities.

Individual identified as Researchers have specific disclosure, training, and compliance obligations under this procedure. Individuals who are uncertain whether they qualify as a Researcher are encouraged to disclose and to consult with RIC.

Disclosure Requirements

When: Researchers must submit a COI Disclosure in the Kuali COI module at the following times:

Upon hire at USU;
Annually (as part of the annual disclosure cycle);
Upon award of a sponsored project, if a financial entity has been previously disclosed;
Within 30 days [15 days if part of a Department of Energy (DOE) proposal or award] of becoming aware of a new or changed reportable interest or activity; and
When requested by RIC.

Whose interests: Depending on the disclosure category, reportable interests may include those of the Researcher, spouse, domestic partner, and/or dependent children as specified in the disclosure form.

Family-member disclosure requirements vary by question and are based on applicable sponsor requirements, institutional requirements, and the nature of the information being collected. Researchers should follow the instructions provided in the disclosure form when determining whose interests must be disclosed.

Reporting time period: Applicable reporting periods are specified in the disclosure form and may vary by disclosure category.

What: USU’s disclosure requirements are designed to collect sufficient information for us to meet federal sponsor requirements, research regulations, university policy, and other disclosure obligations.

Unless otherwise specified, disclosure applies to interests that are related to a Researcher’s institutional responsibilities.

Institutional responsibilities are professional responsibilities performed on behalf of Utah State University. These may include, but are not limited to, research, creative endeavors, teaching, mentoring, clinical activities, outreach, Extension activities, technology commercialization, service, committee participation, professional practice, and other activities conducted as part of your University role.

An interest or relationship is considered related to a Researcher’s institutional responsibilities if it has a reasonable connection to, or could reasonably be perceived to influence, the design, conduct, reporting, interpretation, dissemination, or oversight of research or other institutional responsibilities, including indirect or broadly applicable relationships.

An interest may be considered related to a Researcher’s institutional responsibilities when, for example:

a Researcher owns stock or holds equity in a technology, software, or equipment company whose products are commonly used in research, even if the company is not directly involved in the Researcher’s current project;
a Researcher consults for, advises, or holds a position with an entity that develops tools, platforms, or services used broadly in the Researcher’s field;
a Researcher has intellectual property or a financial interest in an entity that could benefit from research findings, methods, or commercialization pathways, even indirectly;
a Researcher receives materials, data, access, or other support from an external entity that supports or enables research activities.
a Researcher serves on the board of, advises, or holds a leadership role with an organization whose activities overlap with the Researcher's teaching, outreach, Extension, professional practice, technology commercialization, or other University responsibilities.

Specific definitions, examples, thresholds, reporting periods, and family-member disclosure requirements are provided within the Kuali disclosure form and may vary by disclosure category. Researchers should follow the instructions provided in the disclosure form when determining whether information must be disclosed.

The same activity, relationship, appointment, or entity may be reportable under more than one disclosure category. Disclosure in one category does not eliminate the obligation to disclose the same information elsewhere in the disclosure when requested.

Foreign appointments and affiliations
Positions, appointments, affiliations, employment relationships, or other roles with foreign institutions, organizations, governments, professional societies, journals, companies, or other foreign entities, whether paid or unpaid, full-time or part-time, formal or informal.
Foreign talent recruitment program participation
Participation by the Researcher in a Foreign Talent Recruitment Program, as defined in the disclosure form and applicable federal requirements.
External support and resources
Resources, support, facilities, equipment, personnel support, laboratory space, materials, data, software, technology, services, research funding, gifts, or other in-kind support from an external entity not processed through USU Sponsored Programs.
Foreign collaborations
Active research, scholarly, or creative collaborations involving individuals affiliated with institutions outside the United States, regardless of whether the collaboration is funded, compensated, or associated with a sponsored project.
Research conducted through consulting or outside professional activities
Research, scholarly, creative, or other professional activities conducted for or on behalf of an external entity through consulting, employment, advisory services, professional services agreements, or similar arrangements.
Sponsored or reimbursed travel
Travel support provided by a domestic or foreign external entity that is not paid, reimbursed, or administered through Utah State University.
Financial interests
Compensation, remuneration, equity interests, ownership interests, intellectual property interests, royalties, licensing income, commercialization income, or other financial arrangements related to a Researcher's institutional responsibilities, as specified in the disclosure form.
Positions and leadership roles
Positions, appointments, affiliations, leadership roles, fiduciary roles, management roles, advisory roles, board memberships, founder roles, editorial positions, officer positions, trustee positions, or similar responsibilities with external organizations, whether paid or unpaid.
Other outside interests and relationships
Personal, professional, commercial, financial, or other activities, relationships, commitments, or circumstances not otherwise captured in the disclosure categories above that relate to, intersect with, or could reasonably appear to affect a Researcher’s institutional responsibilities or research activities.
- Researchers should disclose any activity, relationship, appointment, affiliation, support arrangement, financial interest, or commitment that could reasonably be related to their institutional responsibilities or research activities or create an actual, potential, or perceived COI or COC.
- A conflict of interest exists when a Researcher's financial, professional, or personal interests could directly or indirectly affect, or reasonably appear to affect, the Researcher's professional judgment, objectivity, or institutional responsibilities.
- A conflict of commitment exists when external activities, whether paid or unpaid, interfere with or reasonably appear to interfere with an individual's ability to fulfill their institutional responsibilities.
NSF-Specific Documentation Requirements
For NSF proposals and awards, Researchers must provide supporting documentation for foreign activities disclosed in the COI disclosure and in Current and Pending (Other) Support, as required by NSF and University procedures.
- Supporting documentation may include information related to foreign appointments, affiliations, research support, resources, collaborations, participation in foreign talent recruitment programs, and other foreign activities, whether paid or unpaid.
- Additional Guidance

All disclosures must include sufficient detail to allow RIC to assess the nature, scope, magnitude, and relatedness of the disclosed interest, activity, relationship, appointment, affiliation, support, other outside interest, including its connection to the Researcher’s institutional responsibilities and research activities.

Initial Review and Screening of Disclosures

All disclosures submitted by Researchers are reviewed by RIC. Most disclosures are reviewed administratively to determine whether additional assessment, clarification, or management is required. Disclosure does not mean a conflict exists; rather, it allows the University to evaluate potential conflicts and comply with applicable sponsor and regulatory requirements.

Disclosures that report no outside interests or relationships requiring disclosure are generally considered complete and require no further review unless selected for audit of follow-up.

Disclosures that report one or more outside interests or relationships are reviewed by RIC to determine whether additional assessment or management is required.

As part of this review process, disclosed entities, affiliations, activities, and collaborations may be screened for research security, export control, sanctions, embargoes, and other compliance considerations. Additional guidance is available in the USU Export Control Manual, applicable research security guidance, and Policy 4109: Export Controls.

The University may review or audit any disclosure, including those reporting no outside interests, to ensure completeness, accuracy, and compliance with university policies, sponsor requirements, and regulatory obligations. Reviews may occur randomly or may be triggered by information identified through other university processes, sponsor requirements, or newly available information.

Review or audit of a disclosure does not imply the existence of a conflict or noncompliance.

Conflict of Interest Determination

RIC evaluates all disclosed interests using a risk-based approach and considers the totality of the circumstances.

A COI exists when a personal, financial, professional, or institutional interest has the reasonable potential to compromise, or appear to compromise, the objectivity, integrity, or independence of research or other institutional responsibilities.

All disclosed outside interests and relationships are evaluated using the same COI assessment criteria, regardless of sponsor, funding source, or whether an activity is externally sponsored. USU applies all applicable federal regulations, sponsor guidance, and recognized best practices to ensure consistent, fair, and defensible determinations.

In determining whether a COI exists, RIC considers the totality of circumstances, including but not limited to:

Financial Interests and Research Relationships

financial interests related to the research
relationship to design, conduct, or reporting

Position and Authority

PI roles
budget authority
hiring authority

Students, Trainees, and Power Imbalances

students
postdocs
mentoring relationships

Research and Institutional Risks

human subjects
sensitive research
external commitments

University Decision-Making

vendor selection
purchasing
subawards

Foreign Activities and Research Security

foreign affiliations
foreign compensation
export control considerations

Appearance Concerns

reasonable observer standard

If a potential COI, or the appearance of one, is identified, the Researcher and the appropriate supervisor (typically the department head) will be notified so that a COI Management Plan can be developed, when required.

Additional Sources of COI Review

Potential conflicts may also be identified through other University activities. These reviews do not replace disclosure obligations and are evaluated using the same COI assessment framework.

Sponsored Projects
COI review may occur during proposal submission, award review, or project management when relationships, outside interests, sponsor arrangements, student involvement, or other circumstances suggest a potential conflict. When required, an up-to-date disclosure and approved Management Plan must be in place before award setup or the start of research activities.
IRB, IACUC, or IBC Review
Potential conflicts may be identified during protocol review, including financial interests, investigator roles, power imbalances, or other factors that could affect research objectivity or participant protection. When required, research may not proceed until an appropriate COI Management Plan is approved.
Technology Transfer and Intellectual Property Activities
Potential COIs may be identified through invention disclosures, licensing activities, start‑up formation, commercialization efforts, or relationships involving entities seeking to license or commercialize USU intellectual property.
Anonymous or Confidential Reports
Potential conflicts may be identified through confidential or anonymous reports, including reports submitted through university reporting mechanisms.
University reporting mechanisms include, but are not limited to:
- direct communication with RIC; or
- reports submitted through the University’s EthicsPoint reporting system.
Researchers are encouraged to contact RIC directly with questions or concerns about potential COIs; consultation with RIC does not imply wrongdoing.
Requests for review submitted by University Officials:
Potential conflicts may also be referred to RIC by Researchers, supervisors, compliance offices, procurement personnel, deans, vice presidents, or other University officials.

COI Management Plan

When a potential or actual COI is identified, RIC may develop a COI Management Plan to address identified risks and support continued research activity and other institutional responsibilities through appropriate safeguards.

A management plan is a written document specifying actions and safeguards designed to prevent a COI from influencing decision-making or performance of institutional responsibilities, including the design, conduct, reporting, and funding of research.

RIC will prepare a written COI analysis, which includes:

a brief description of the identified conflict;
an assessment of the potential risks to institutional decision-making or research objectivity, integrity, participants, students, or public trust; and
a proposed COI Management Plan tailored to the specific circumstances.

The Researcher and department head or other supervising official, with assistance from RIC, will review the proposed COI Management Plan and may provide feedback or identify concerns. COI Management Plans are intended to support continued research or institutional activity whenever possible through reasonable safeguards. Researchers who identify a conflict independently may submit a proposed COI Management Plan for review; such plans will be evaluated using the same criteria and risk‑based framework.

COIs are managed using a risk‑based approach, with management conditions tailored to the nature of the conflict and the associated risks to research objectivity, integrity, and public trust.

Potential Management Strategies

Management strategies may include, but are not limited to:

public disclosure of COI (e.g., in presentations or publications);
disclosure of the conflict to students, trainees, collaborators, or research participants when appropriate;
appointment of an independent monitor capable of overseeing the design, conduct, and reporting of the research;
modification of the research plan;
change of personnel roles, or disqualification from participation in all or part of the research;
reduction or elimination of the financial interest (e.g., divestiture of equity);
severance of the relationships that gave rise to the conflict.

When a COI involves students, trainees, or others in dependent or evaluative relationships, management plans may require additional safeguards, including independent oversight or role separation.

Conflict Manager

When a COI Management Plan is approved, the Researcher’s department head or another designated individual will serve as the Conflict Manager, unless otherwise specified by RIC.

The Conflict Manager is responsible for implementing, monitoring, and documenting compliance with the approved COI Management Plan. Because department heads and supervisors are familiar with departmental operations, student involvement, and project oversight, they are typically best positioned to translate COI Management Plan requirements into effective and practical safeguards.

The role of the Conflict Manager includes, but is not limited to:

reviewing and understanding the approved COI Management Plan and associated conditions;
determining how approved safeguards will be implemented within departmental workflows (without modifying the approved plan);
coordinating with the Researcher, students, and relevant offices as needed to ensure safeguards are in place;
monitoring ongoing compliance with the COI Management Plan through periodic check ins and review of relevant activities or documentation;
maintaining brief records demonstrating implementation and oversight;
reporting to RIC any concerns related to noncompliance, changes in circumstances, or effectiveness of the COI Management Plan;
completing required Conflict Manager compliance reports, typically on an annual basis or as otherwise requested.

Conflict Managers are expected to act objectively, avoid conflicts of their own, and maintain appropriate confidentiality in carrying out this role.

COI Management Plan Approval and Ongoing Responsibilities

The final COI Management Plan will be reviewed and approved by:

the Researcher
the Researcher’s department head and/or associate dean of research or dean, as appropriate;
RIC; and
other relevant parties (e.g., IRB, IACUC, RCIRSC, or sponsor), when deemed necessary by RIC based on the nature of the conflict or applicable requirements

If required, the COI Management Plan may be shared with relevant University units or external entities, including but not limited to Technology Transfer Services (TTS), IRB, IACUC, or funding agencies.

Researchers are responsible for implementing and complying with their approved COI Management Plan. Conflict Managers share responsibility for monitoring compliance and must review the COI and COI Management Plan at least annually.

To support this review, Researchers and department heads will receive an annual reminder from RIC to review, and if necessary, renew their COI Management Plan.

Both the Researcher and the supervisor must report to RIC within ten (10) days any changes, incidents, or circumstances that affect, or could reasonably appear to affect, the conflict or its management. Supervisors should consult RIC promptly regarding any concerns related to compliance or effectiveness of the COI Management Plan.

Illustrative Examples (Non-Exhaustive)

These examples are provided for guidance only; management decisions are based on the specific facts and risks of each case.

Procurement and University Business Decisions: Researchers who have a financial interest in, receive compensation from, or otherwise have a relationship with an entity involved in a University purchasing, contracting, vendor selection, subaward, or other business decision should disclose the relationship and avoid participating in decisions that could benefit the entity. When recusal is not feasible, RIC may require alternative safeguards to ensure the decision-making process remains objective and appropriately documented.
Consulting activities: A Researcher consults for a company that develops equipment used in the Researcher's field of study. RIC may require disclosure of the relationship, review of sponsored projects involving the company, and management measures addressing students, publications, or purchasing decisions.
Student supervision and financial benefit: A Researcher supervises a student who is working on activities that may benefit a company in which the Researcher has a financial interest. Additional safeguards may be required to address power imbalances and protect the student's academic interests.

Unmanageable Conflicts of Interest

USU's preference is to manage identified COIs through reasonable safeguards whenever possible. In some circumstances, however, a conflict may be so significant that it cannot be adequately managed through disclosure, oversight, recusal, monitoring, or other management measures.

When RIC determines that a conflict may be unmanageable, the matter will be referred to the for review and final determination.

Examples may include situations where a Researcher's financial, supervisory, or personal interests cannot be adequately separated from their University responsibilities, such as directing University funds, subawards, contracts, consulting agreements, or other University-supported activities to a business owned or controlled by a student, trainee, or other individual whose academic progress, funding, employment, or evaluation depends on the Researcher.

Determinations are made on a case-by-case basis based on the specific facts and circumstances. Identification of a potentially unmanageable conflict does not automatically prohibit an activity, but additional review, modification of the activity, elimination of the conflict, or discontinuation of the activity may be required.

Human Subject Research

When a potential or actual COI involves research with human participants, additional oversight may be required to ensure appropriate coordination between COI management and human subjects protections.

RIC is responsible for developing and approving COI Management Plans, including those involving human subjects research. When a COI relates to research reviewed by the IRB, RIC will coordinate with the IRB as appropriate.

The IRB may impose additional requirements or participant protections as conditions of IRB approval. IRB requirements and COI Management Plan requirements operate independently and must each be followed, as applicable.

Researchers must promptly report any changes, incidents, or circumstances that affect, or reasonably appear to affect, participant protections, research integrity, or compliance with an approved COI Management Plan.

When developing COI Management Plans involving human participants, RIC applies a heightened, risk-based approach that prioritizes participant protection, transparency, research integrity, and public trust. Management measures may include disclosure of the conflict, independent oversight, role restrictions, recusal from conflicted activities, additional monitoring, or other protections appropriate to the circumstances.

Training

All Researchers are required to complete University‑approved COI training to support understanding of disclosure responsibilities, sponsor requirements, and compliance with approved COI Management Plans.

Researchers must complete COI training:

upon hire at USU;
annually, as part of the University’s required compliance training cycle;
before approval of a COI Management Plan, if training is not current;
before participating in research subject to sponsor‑specific COI training requirements, including research funded by the Public Health Service (PHS) or the U.S. Department of Energy (DOE);
when COI training is updated due to changes in applicable policies, procedures, regulations, or sponsor requirements; or
when additional training is required to address identified compliance concerns or support implementation of disclosure or COI Management Plan requirements.

Completion of required training is a condition of compliance with this procedure and applicable sponsor requirements.

Training is intended to help Researchers understand and meet their responsibilities and does not, by itself, indicate the existence of a conflict or noncompliance.

Failure to maintain required COI training may result in delays or restrictions on the review or approval of disclosures, COI Management Plans, proposals, awards, protocols, or other research activities until training requirements are satisfied.

Research Conflict of Interest Review Sub-Committee (RCIRSC)

RIC is responsible for making research COI determinations and developing appropriate COI Management Plans using a risk‑based, institutional framework.

In exceptional circumstances, and only when additional independent or research‑specific input would materially assist in resolving a matter, RIC may convene an ad hoc Research Conflict of Interest Review Sub‑Committee (RCIRSC) after consultation with and approval from the VPR

Examples of circumstances that may warrant consultation with the RCIRSC include:

inability to reach an agreement on an appropriate COI Management Plan;
proposed management measures that would significantly restrict or discontinue an area of research or scholarly activity;
conflicts presenting heightened institutional, reputational, or financial risk; or
situations where additional expertise or perspective would support development of an effective and defensible COI Management Plan.

The RCIRSC serves in an advisory capacity only. It may provide recommendations regarding risk assessment and management options but does not determine whether a conflict exists and does not serve as the final decision‑making authority.

If a conflict cannot be effectively managed through reasonable safeguards, the matter may be referred to the VPR for final review and determination.

Routine COI determinations and COI Management Plans are resolved administratively by RIC and do not require committee review.

Noncompliance

USU’s approach to noncompliance emphasizes education, corrective action, and cooperation. Most instances of noncompliance are addressed through communication, clarification of expectations, and support for timely correction.

Researchers are responsible for maintaining current disclosures, completing required training, providing requested information, and complying with approved COI Management Plans. The University uses reminders, follow‑up communications, and other compliance support measures to promote timely disclosure updates and ongoing compliance.

Failure to disclose required outside interests, complete required training, comply with an approved COI Management Plan, or fulfill other obligations under this procedure may result in corrective or administrative action consistent with University Policy 2301, applicable sponsor requirements, and other relevant University policies.

Individuals assigned compliance oversight responsibilities, including Conflict Managers, are also expected to fulfill those responsibilities as required under this procedure.

Sanctions, when warranted, are subject to applicable due process protections, including those set forth in USU Policy 4006: Academic Due Process – Sanctions and Hearing Procedures.

Compliance Monitoring and Audits

USU maintains records related to COI disclosures, reviews, determinations, and COI Management Plans in accordance with applicable federal regulations, sponsor requirements, and University policies.

COI information may be reviewed or disclosed, as required, in connection with:

internal compliance reviews;
sponsor monitoring or audits;
regulatory or governmental audits;
accreditation, assurance, or other institutional compliance activities.

Researchers may be asked to provide clarification, supporting documentation, or information related to previously disclosed interests, disclosure responses, or compliance with a COI Management Plan.

Compliance monitoring and audits do not create additional disclosure obligations beyond those described in this procedure. Rather, they help verify that disclosures were complete and accurate, determinations are appropriate, and COI Management Plans are implemented and followed when required.

Additional Information

Related USU Policies

Related Guidance

Forms and Systems

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