National Science Foundation (NSF) FCOI Requirements

►Regulatory Requirements. "NSF encourages the increased involvement of academic researchers and educators with industry and private entrepreneurial ventures, but recognizes that such interactions carry with them an increased risk of conflicts of interest" To address this risk, the NSF Award and Administration Guide contains NSF's conflict of interest requirements for grantee organizations. NSF Award and Administration Guide, Chapter IX(A) - Grantee Standards, Conflict of Interest Policies (NSF 20-1, June 1, 2020).

  • Mandate. NSF requires "that all conflicts of interest for each award be managed, reduced or eliminated prior to the expenditure of the award funds." (AAG  IX.A.1)
  • Applicability:  Research or Educational Activities Funded or Proposed for Funding by NSF. NSF establishes standards to be followed by "each grantee maintain an appropriate written and enforced policy on conflict of interest..." that requires disclosure of significant financial interests by "investigators...responsible for the design, conduct, or reporting of research or educational activities funded or proposed for funding by NSF." (AAG  IX.A.1-2)

►Auburn University NSF FCOI Procedures. AU has adopted and maintains NSF FCOI Procedures.  

  • In order for investigators at Auburn University to ensure that no unresolved conflict exists between their outside financial interests and their commitment to their research or educational activities funded by the National Science Foundation (NSF) and/or their proposed protocol for the use of human subjects in research, each "Investigator" must disclose their Significant Financial Interests and those of their immediate family:
  1. that would reasonably appear to be affected by the research or educational activities funded or proposed for funding by NSF; or
  2. in entities whose financial interests would reasonably appear to affected by such activities

►Principal Investigators' Responsibilities for Oversight of Filing Disclosure Questionnaires.

  • Continuing Responsibilities. On a timely basis, from the proposal stage throughout the duration of a project subject to the NSF FCOI requirements, Principal Investigators are responsible for: 
    1. Identifying "Investigators" on a proposal, award, and modification to the scope of work, and
    2. Ensuring "Investigators" submit COI Disclosure Questionnaires.
  • Identifying "Investigators."  "The term 'Investigator' means the principal investigator, co-principal investigators/co-project directors, and any other person identified on the proposed project who is responsible for the design, conduct, or reporting of research or educational activities funded or proposed for funding by NSF."  (NSF Award and Administration Guide, IX.A.). Please consult Guide to Identifying "Investigators" Subject to NSF COI Regulations.
    • The PI, Co-PI, PD, and Co-PD named in the proposal for funding, the award, a progress report, an award modification, or in a subaward, subgrant, or subcontract are always considered an Investigator.

►Submitting Disclosure Forms. 

  • As of October 2019, Auburn University requires NSF "Investigators" to complete a COI Disclosure at least on an annual basis.
  • Each "Investigator" is required to update their Disclosure Form at certain points during the reporting year:
    • Before the processing of a new proposal if the participation in the new proposal could create a conflict not previously reported, and
    • Within thirty (30) days of discovering or acquiring a new Significant Financial Interest for themselves or their Immediate Family, and
    • Upon request by the Authorized Institutional Official as needed to ensure compliance with the AU FCOI policy.
  • Multiple Research Sponsors.  If you have multiple funding sponsors, you do not need to submit multiple disclosure questionnaires at the same time and/or for the same purpose.
    • If you are both a PHS and NSF Investigator, you must submit only one annual disclosure questionnaire.  Depending on the requirements of your multiple funding sources and/or AU policy, you may need to revise your disclosure during the year.
    • For example, if you are a PHS Investigator and have submitted an annual disclosure questionnaire, you do not need to submit a new questionnaire upon submitting a proposal to NSF or upon receiving an award from NSF or a private sponsor unless the specific circumstances may create a COI not previously disclosed.

►How to Disclose: Online via COI-SMART.

  • COI-SMART Users.
    • Accessing COI-SMART: Use single sign-on to login to COI-SMART or click on the COI-SMART button in AU Access under the My Funding tab.
    • Helpful Guide. Use this Quick Reference Card to login and complete your Disclosure Questionnaire in COI-Smart.  It includes FAQs.
    • Recertification/Revision. Use this Step-by-Step Guide to avoid common, time-consuming errors!
    • Annual Disclosure. To complete your annual Disclosure Questionnaire, access COI-SMART and:
      • Click "My Questionnaires" in the left sidebar.
      • Click the most recent Questionnaire, found at the end of the list.
      • Proceed through the questions, provide the Certification at the end and submit the Questionnaire.

► Completing FCOI Training.