Conflict of Interest FAQs

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.

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.

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 “significantfinancial interest” that requires disclosure.  The basic thresholds for disclosure depend on the funding agency (see the policies for more specific details):

Public Health Service Agency
(and those following PHS regs)

Related to the investigator’s institutional responsibilities

Examples: Non-UNH salary; equity or other ownership interests; intellectual property

Publicly Traded Entity:  Aggregate value of more than $5000 remuneration and equity
Non-Publicly Traded Entity:  Aggregate value of more than $5000 or ownership/equity of more than 0%

All Other External Funding Sources

Could affect or be affected by the investigator’s funded research activities

Examples: Non-UNH salary; equity or other ownership interests; intellectual property

Aggregate value of more than $10,000, ownership/equity of more than 5%

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.

Grant/Contract Administrator

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.

online training module

Melissa McGee, Compliance Officer
Research Integrity Services
melissa.mcgee@unh.edu
603-862-2005

Julie Simpson, Director
Research Integrity Services
julie.simpson@unh.edu
603-862-2003

View Conflict of Interest Knowledge Base

The Knowledge Base contains forms, instruction and training material, minutes, policies, tools and other resources to support your research efforts by topic area.