Which UNH policies address conflicts of interest?

UNH Conflict of Interest and Commitment Policy (see Section 7)
UNH Financial Conflict of Interest in Research for PHS-Funded Projects (PHS) Policy
UNH Financial Conflict of Interest in Research Policy
UNH Management of Equity Interests in Start-Up Companies Policy
USNH Purchasing Policy (see Section B.4)
USNH Nepotism Policy (see Section 6)

What is a “conflict of interest?”
A “conflict of interest” occurs when professional actions or decisions are influenced by personal considerations, financial or otherwise; the term also includes unauthorized use or misuse of UNH resources in the course of an external activity.

A related concept is “conflict of commitment,” which occurs when time or effort devoted to external activities by faculty, extension educators, or staff interferes with fulfillment of their assigned UNH responsibilities.

Who must comply with the Conflict of Interest policies?
The Conflict of Interest and Commitment policy (see the link above) applies to all UNH faculty, extension educators, and staff.

Anyone who is an “investigator” on an externally funded research project, whether funded by a grant, a contract, or other arrangement, must also comply with the Financial Conflict of Interest in Research (“FCOIR”) policies (see the links above).  An “investigator” is defined as the project director or principal investigator and any other person, regardless of title or position (e.g., consultants, unpaid collaborators), who is responsible for the design, conduct, or reporting of research funded by external sources, or proposed for such funding.

What is a “financial conflict of interest in research” (FCOIR)?
A “financial conflict of interest in research” exists when it can be reasonably determined that an investigator’s personal financial concerns could directly and significantly influence (or be influenced by) the design, conduct, or reporting of sponsored research activities.  UNH faculty and staff have an obligation to scrupulously maintain the objectivity of their research and avoiding any conflict of interest – financial or otherwise.

What is a “significant financial interest” for FCOIR that requires disclosure?
A financial interest can be comprised of anything of monetary value, whether or not the value is readily ascertainable.  Under the UNH FCOIR policies, an investigator must file a form with the Office of the Senior Vice Provost of Research, if the investigator (or his/her spouse, domestic partner, or dependent child) has a “significant financial interest” that requires disclosure.  The basic thresholds for disclosure depend on the funding agency (see the policies for more specific details):

Does a subawardee on a sponsored project have to comply with the FCOIR regulations if UNH is required to do so?
Yes.  UNH must flow-down FCOIR terms, along with other award terms, to any of our subawardees or subcontractors.  A subrecipient may elect to follow UNH’s PHS FCOIR policy if the sub has not enacted its own policy.  Subawards or subcontracts will not be issued until all FCOIR issues have been resolved.  Contact your Grant/Contract Administrator to discuss when and how this must be accomplished.

Is training available?
Training and education are important components of UNH’s compliance activities.  Both in-person training and an online training module are available.

The online training module provides a general overview of the conflict of interest policies and regulations, and is designed to assist faculty, staff and students with acquiring a basic level of understanding.  The module takes approximately 45 minutes, and includes a brief series of quiz questions.  In-person training is also available for any individual or group of faculty, staff or students who would like more specific guidance regarding the application of FCOIR at UNH.  Please contact Research Integrity Services (see below) to schedule a training session.

Who can I contact regarding Financial Conflict of Interest in Research at UNH?
 

Melissa McGee, Compliance Officer                   Julie Simpson, Director
Research Integrity Services                                  Research Integrity Services
melissa.mcgee@unh.edu                                     julie.simpson@unh.edu
603-862-2005                                                        603-862-2003