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 “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.

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.

UNH faculty and staff have an obligation to scrupulously maintain the objectivity of their research and avoiding any conflict.

The Conflict of Interest and Commitment policy 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”) policy.  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.

A financial interest can be comprised of anything of monetary value, whether or not the value is readily ascertainable. Under the UNH FCOIR policy, an investigator must file a form with Research Integrity Services if the investigator (or his/her spouse, domestic partner, or dependent child) has a “significant financial interest” that requires disclosure.

UNH policy sets a basic disclosure requirement with which all investigators must comply, but some sponsors may have more rigorous disclosure requirements that apply.

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 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.

Find your Grant/Contract Administrator

Training and education are important components of UNH’s Conflicts of Interest compliance. Both in-person training and online training are available.

For online training, USNH uses the CITI Program online Conflicts of Interest for Externally Funded Researchers course.

To access a USNH CITI Program courses, individuals need to use University System of New Hampshire as their organization when logging into the CITI Program (not University of New Hampshire). See this Guidance for Accessing the CITI Program Courses via USNH Single Sign On.

Training certificates are valid for four years from the date of completion.

(The former UNH Conflicts of Interest and Commitment training module was retired on August 30, 2024. If an investigator completed the UNH module prior to that date, the certificate will still be accepted until the four-year expiration date.)

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 policy at USNH. To schedule a training session, please contact Research Integrity Services.

CITI training