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Conflicts of Interest

Conflicts of Interest

Conflict of Interest (COI) relates to financial or other interests or relationships that compromise, have the potential for compromising, or may have the appearance of compromising an employee’s objectivity in fulfilling their university duties or responsibilities. UNCW utilizes three disclosure forms described below that are stipulated by UNCW policy and are required for all full-time, part-time, temporary faculty and EHRA non-faculty staff or who are senior/key investigators on externally-funded research projects. You can learn more about UNCW's COI Policy here.

The COI team in the Research Integrity Office (RIO) coordinates UNCW's COI compliance efforts. RIO offers all operations virtually. We look forward to assisting you!

Submitting COI Disclosures

Need to submit an Annual disclosure or notice of External Professional Activity for Pay (EPAP)?  Click here to log into the OSPREY research administration system with your usual UNCW credentials!

COI NEWS & UPDATES

The Provost's office sent an annual email on 10/3/23 regarding the Annual Conflict of Interest disclosure requirement and set an October 18, 2023 deadline for submission.  All faculty positions and EHRA non-faculty positions are subject to this annual reporting requirement.  This includes full time, part time, permanent and temporary employees, as well as faculty on phased retirement.  Certain SHRA employees are also subject to this requirement if they teach or serve in interim EHRA positions.  More details about this requirement are provided below.  If not submitted by the deadline, subject employees will receive reminders until the form is submitted.  UNCW now uses "OSPREY" (Online Sponsored Programs and Research Enterprise sYstem) for grant and contract administration, conflict of interest reporting, and IRB applications. 

You can find quick instructions on how to submit your Annual COI disclosure below.  If you would like hands-on assistance submitting your annual COI form, please contact COI staff at coi@uncw.edu to set up a Zoom session and we will be happy to assist you with completing your form.

OSPREY

SUBMIT COI FORMS ON OSPREY 

Annual COI Disclosures

All faculty and EHRA non-faculty employees must complete an Annual Conflict of Interest Disclosure through an online disclosure management system called OSPREY to report their activities, interests and relationships or lack thereof. Certain SHRA positions are also subject to this requirement if an SHRA employee teaches a course or serves in an interim EHRA position.

Employees subject to this requirement include full time and part time, permanent and temporary, research active and not research active, faculty, EHRA non-faculty, and certain SHRA positions (those who teach classes or serve in interim EHRA positions), as well as faculty who are on phased retirement.  Employees who are subject to this requirement must submit a disclosure annually even if they have no activities to report, their previously reported activities have not changed, or they already have an approved management plan in place for previously-reported activities.  This requirement is in addition to disclosures submitted for specific funded projects.

Quick guide to submit an Annual COI Disclosure:

  1. Login to OSPREY
  2. Click Conflict of Interest on the left navigation menu of the OSPREY Home screen
  3. Click Create/Update Disclosure
  4. Find the first row of buttons under your contact information and click Create or Update ANNUAL Disclosure
  5. Instructions are provided throughout the form for your reference
  6. Complete all questions and click the Click to Lock and Submit button when ready to submit

Need more resources?

Please email coi@uncw.edu to request step-by-step instructions with screen shots or to schedule a Zoom session for a demonstration or hands-on assistance.

External Professional Activities for Pay

An External Professional Activities for Pay (EPAP) is defined as any activity that is not included within an employee's UNCW responsibilities, is undertaken for compensation by a non-UNCW entity, and is based upon the professional knowledge, experience and abilities of the employee.

Requests for approval to engage in an EPAP must be submitted at least ten (10) days prior to engaging in the activity. When subject employees report EPAPs in OSPREY, the request is routed to the employee's supervisor for approval. If the request is denied, per UNCW policy the employee has the right to appeal the decision.

If you are a supervisor and you receive a notice informing you that an employee under your supervision has submitted an EPAP for your review, please log into OSPREY to conduct the review.

Quick guide to submit an EPAP:

  1. Login to OSPREY
  2. Click Conflict of Interest on the left navigation menu of the OSPREY Home screen
  3. Click Create/Update Disclosure
  4. Find the second row button under your contact information and Click Disclose EPAP
  5. Instructions are provided throughout the form for your reference
  6. Complete all questions and click the Click to Lock and Submit button when ready to submit

Differences Between Annual & EPAP

It's not necessary to disclose an activity on both the Annual COI and EPAP forms.

The Annual COI disclosure form is used to report activities or relationships that you or a member of your family have with non-UNCW entities whose operations are related or potentially related to your university responsibilities.  These activities or relationships may be paid or unpaid, and the main concern is determining if the activity/relationship introduces bias, has the potential to introduce bias, or has the appearance of introducing bias into university decisions and duties.  Disclosure forms that indicate an activity or relationship are initially reviewed by COI staff and are forwarded to the discloser's supervisor as needed for a determination.

The Notice of EPAP is used to seek approval from the discloser's supervisor of an upcoming paid professional activity.  Unlike relationships with entities reported on Annual COI disclosure forms, the non-UNCW entity contracting an EPAP has no association with UNCW.  This often occurs when UNCW faculty are hired to perform consulting work by local governments, public schools, or other organizations unassociated with UNCW. 

Project-Specific COI Disclosures

When conducting funded research at UNCW, there is a requirement for researchers to disclose the financial or other interests related to the funded project and complete mandatory training on financial conflict of interest. When investigators submit proposals through OSPREY, they will be contacted by RIO staff on any compliance requirements that need to be met, including information on how to submit a disclosure form that is specific to the funded project.

Project-specific disclosures are submitted through OSPREY.

Quick guide to submit a Project-Specific COI Disclosure:

  1. Login to OSPREY
  2. Click Conflict of Interest on the left navigation menu of the OSPREY Home screen
  3. Click Create/Update Disclosure
  4. Find the third row button under your contact information and Click Disclose Project
  5. Be sure to click Add Project to identify the project to which the disclosure pertains.
  6. Instructions are provided throughout the form for your reference
  7. Complete all questions and click the Click to Lock and Submit button when ready to submit

Training & Quiz Completion Requirements

Every investigator on funded projects, including sub-recipient investigators, are required to complete conflict of interest training prior to engaging in externally-funded research. The COI training must be completed at least every four years. If you are unsure of when your training needs to be updated, please contact COI staff.
Complete Your Training

Federal Regulation on COI in Funded Research

Specific conflict of interest training and reporting requirements may be required when UNCW investigators apply for and/or receive funding from certain federal agencies, including the Public Health Service (PHS) Awarding Components (includes NIH and SAMHSA), the National Science Foundation (NSF), the U.S. Department of Justice (DOJ), and the U.S. Department of Energy (DOE).  UNCW will comply with these requirements.

The U.S. Department of Health and Human Services issued the final rule that amends the Public Health Service (PHS) regulations on Responsibility of Applicants for Promoting Objectivity in Research for Which PHS Funding is Sought [PDF] (45 C.F.R. Part 50) and Responsible Prospective Contractors (45 C.F.R. Part 94).

The National Science Foundation (NSF) updated its Proposal & Award Policies & Procedures Guide (PAPPG) (NSF 23-1) on January 30, 2023 that includes NSF's conflict of interest policies in Chapter IX: Recipient Standards.

The Department of Justice requires in its Grant Application Resource Guide recipients and subrecipients of funding to have conflict of interest policies in place, and either certify that they have identified no personal, financial or organizational conflict of interests that could affect the independence or integrity of the research, including the design, conduct and reporting of the research or provide a specific description of the conflict(s).

The Department of Energy issued an interim Conflict of Interest Policy Requirements for Financial Assistance on December 20, 2021 that largely aligns with the PHS policy linked above.

 

Organizational COI

UNCW is committed to identifying, avoiding, and/or managing actual or perceived conflicts of interest relating to its research activities consistent with federal laws and regulations. In conducting federal research and contracting activities, University members have a responsibility to comply with this guidance.

 A unique type of conflict of interest may arise when members of UNCW assist in the development of new federal programs or federal contract specifications, and UNCW later competes for federal support through those new programs or contracts. This type of conflict of interest has been named “Organizational Conflict of Interest” (OCI) and is described in Federal Acquisition Regulation (FAR) Subpart 9.5 “Organizational and Consultant Conflicts of Interest”

Federal agencies often invite university faculty members to provide advice and technical assistance. Such public service is part of UNCW’s mission and is encouraged. However, there may be the potential for an OCI in such cases. For example, if a faculty member is on a panel that provides input for a new Request for Applications that will be put forth in the future, an OCI may exist if UNCW then submits an application. Although the important contributions that faculty members and other UNCW personnel may make in advising federal agencies must not be discouraged or diminished, any OCI must be managed.

UNCW seeks to identify and manage OCI in a manner consistent with FAR Subpart 9.5. This guidance applies to all University members, to include faculty, staff, and students.

Appeals

A Covered Employee may appeal a supervisor’s decision regarding Conflicts of Interest and Conflicts of Commitment (External Professional Activities for Pay). The Covered Employee shall not proceed with the proposed activity but may appeal that decision to the administrative officer to whom the department chair or other supervisor reports (e.g., dean), and then if needed to the chancellor or the chancellor’s designee.

Appeals must be made in writing within five (5) business days of receipt of the decision to be appealed. For appeals related to Conflicts of Interest or Commitment, the Covered Employee bears the burden of demonstrating to the officer’s satisfaction that the activity at issue is not a Conflict of Interest or Commitment or that it can be managed differently.

A decision on any such appeal shall be given by the administrative officer, or the chancellor or chancellor’s designee, as appropriate, to the Covered Employee within ten (10) business days of the date on which the appeal is received. The decision of the chancellor or chancellor’s designee is final.

Feedback

Tell the COI team in the Research Integrity Office how we're doing on this quick, 4-question survey!

Additionally, please be aware that the Office of Internal Audit at UNCW provides links for reporting allegations of fraud, waste, abuse, or mismanagement of funds.  Click on the link below to report concerns.

Report Fraud

Resources

Contact Us

Conflict of Interest (COI)

Phone: (910) 962-7774

coi@uncw.edu

Institutional Official

Dr. Stuart Borrett

910.962.7430

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