Conflicts of Interest

For all sponsored projects, Principal Investigators must submit SFI Disclosure Forms to the CCO, with a copy to the Grants Officer, before a proposal or application is submitted to an External Sponsor. The PI must also comply with any disclosure and approval procedures required by the External Sponsor or the University in connection with any such proposal or application. All other Investigators must submit SFI Disclosure Forms to the CCO, with a copy to the Grants Officer, at their College prior to the expenditure of any awarded funds or support.

1. The CCO shall complete a FCOI Determination Report, setting forth their determination:
   1. Whether the investigator’s SFI is related to the investigator’s research; and, if so,
   2. Whether the Investigator’s SFI is related to PHS-funded research; and,
   3. Whether the SFI constitutes a FCOI, as defined in section 6.12 of CUNY Conflict of Interest Policy.
2. Whether or not the CCO determines that a FCOI exists, the CCO shall promptly forward the documentation to the University Director for Research Compliance, the College Provost, the investigator, and, if the case involves a sponsored project administered through the CUNY Research Foundation, the Legal Department of the Research Foundation.
   1. The Chair of the Conflicts Committee shall then review and indicate whether or not they concur with the CCO’s determination. If the Chair determines that a FCOI exists, the FCOI will be reviewed as follows:
      1. The University Director for Research Compliance shall promptly schedule a meeting of the Conflicts Committee.
      2. The Conflicts Committee shall develop a conflict management and oversight plan that specifies the actions required to manage the FCOI. This plan must be developed and implemented prior to the expenditure of any related research funds.
      3. The Conflicts Committee Administrator shall document the Committee’s plan and promptly distribute it to all affected parties, including the College Provost, the investigator, the college Grants Officer, and, if the case involves a sponsored project administered through the CUNY Research Foundation, the Legal Department of the Research Foundation.
         • If the research in question involves human subjects, the Conflicts Committee Administrator shall also notify the appropriate Institutional Review Board (IRB).
         • If the research in question involves animal subjects, the Conflict Committee Administrator shall also notify the appropriate Institutional Animal Care and Use Committee (IACUC).
      4. Whenever the Conflicts Committee develops and implements a management and oversight plan, the Office of the Vice Chancellor for Research, with the assistance of the CCO, shall monitor the investigator’s compliance with the plan on an ongoing basis until the completion of the research project.