Sponsored Programs & Research Compliance

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Conflict of Interest

Conflict of Interest (COI) relates to situations in which financial or other personal considerations, circumstances, or relationships may compromise, may involve the potential for compromising, or may have the appearance of compromising an employee’s objectivity in fulfilling their University duties or responsibilities, including research, service and teaching activities and administrative duties. 

Need to submit a disclosure? Go to the AIR (Activities, Interests and Relationships) system.

Looking for a Specific COI Topic?

UNCW COI NEWS AND UPDATES:

COVID-19 Update

UNCW business operations are currently functioning as usual, including the UNCW Research Integrity Office.  Please visit UNCW's Best for the Nest website for plans and guidelines for returning to campus.  Other pandemic-related resources for research are posted here.

New Online COI Submission System Coming Fall 2021!

UNCW has entered into a contract with InfoEd Global to develop a new online research administration system that will be called "OSPREY" (Online Sponsored Programs and Research Enterprise sYstem).  OSPREY will replace RAMSeS for grant and contract administration, AIR for COI/EPAP reporting, and IRBIS for IRB applications.  The COI/EPAP module is under development now.  We believe users will appreciate the features OSPREY will offer and we look forward to providing demonstrations in the future!

General COI and EPAP Information

There are three disclosures described below that are stipulated by UNCW policy and are required for all full-time, part-time, temporary faculty and EHRA non-faculty staff.  They are also explained in a Fall 2020 memorandum from Dr. James Winebrake, Provost and Vice Chancellor for Academic Affairs, that you may view by clicking here.

Annual Conflict of Interest Disclosures

All faculty and EHRA non-faculty employees must complete an Annual Conflict of Interest Disclosures through an online disclosure management system called AIR to report their Activities, Interests and Relationships.  This includes full time, part time, and temporary faculty 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, and even if they already have a management plan in place for previously-reported activities.  This requirement is in addition to dislcosures submitted for specific funded projects.

Need to submit an Annual Conflict of Interest Disclosure in AIR?  Click here for step-by-step instructions with screen shots.

Not sure what to report?  Click here for guidance.

Are you a coach who conducts summer camps?  Click here for instructions on how to properly report them.

Are you a supervisor who has to review potential conflicts of interest?  Click here for guidance on different categories of potential conflicts and here for guidance on making determinations on different activities.

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 the AIR system, the request is routed to the employee's supervisor for approval.  If the request is denied, per UNCW COIC policy, the employee has the right to appeal the decision.

Need to submit a request for approval of an EPAP?  Click here for instructions on how to submit an EPAP.

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 the AIR system to conduct the review.  Click here for guidance on reviewing EPAPs.

Project-Specific COI Disclosures

When conducting funded research at UNCW, there is a requirement for researchers to disclose all financial interests related to their institutional responsibilities (teaching, research, professional practice, etc.) and complete mandatory training on financial conflict of interest.  When investigators submit proposals through the RAMSeS system, they receive an email with a link to a disclosure form that is specific to the funded project.

 

Conflict of Interest in Research: Training and Quiz Completion Requirements

Every investigator on funded projects, including subrecipient investigators, are required to complete training prior to engaging in externally-funded research.  The training must be completed at least every four years.  To prepare for the training, you can click here for FAQs on COI policies and procedures, click here for examples of activities you should disclose, and click here for guidance on different COI categories.

 

Appeals

A Covered Employee may appeal a supervisor’s decision regarding Conflicts of Interest, Conflicts of Commitment, and 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 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.

 

Federal Regulation on Conflict of Interest in Research

There are specific conflict of interest training and reporting requirements for Institutions that apply for or receive funding from the Public Health Service (PHS) Awarding Components. 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 (45 C.F.R. Part 50) and Responsible Prospective Contractors (45 C.F.R. Part 94).

 
COI Contact Information

Please be aware that the Office of Internal Audit at UNCW maintains an anonymous reporting tool to facilitate reporting of allegations of fraud, waste, abuse, or mismanagement of funds. Concerns about ethical practices may also be reported anonymously to the State Auditor’s Fraud and Abuse Hotline by calling 1-800-730-8477 or filing a complaint online at http://www.ncauditor.net/HotTips/.