Research Financial Conflict of Interest  

Policy Statement

The University supports its faculty in pursuing research for the public good. To ensure the highest quality research free from bias and FCOI, the University has designed and implemented the following policy based upon federal guidelines.

Reason for Policy

Ensuring objectivity in research has always been a concern to the research community and universities. One of the keys to ensuring the public interest and our best research is to manage possible FCOIs. This policy is intended to comply with the requirements of federal regulations, including the following:

Who Is Governed by this Policy

Faculty, staff and students involved in Sponsored Programs and/or Human Subjects Research.

Policy

Investigator Responsibilities

Investigators are responsible for knowing about and complying with University policies and procedures and federal regulations regarding FCOI, as described in the following sections.

An Investigator who is applying for funds for a federal grant or project must, prior to submission of the proposal and as a condition precedent to receiving Adelphi University approval of the proposal submission, complete a Significant Financial Interest Disclosure form for him/herself, his/her spouse, and his/her dependent children and submit the completed form to the Director of the Office of Research and Sponsored Programs.

It is the responsibility of the Principal Investigator on any Research/Sponsored Program or Institutional Review Board (IRB) protocol to ensure that all Investigators, Key Personnel, and Integral Staff Members involved with the Research/Sponsored Program submit the required Financial Disclosure Forms.

Human Subjects Research Investigator Conflict of Interest

In addition to the annual and amended disclosures set forth in this Conflict of Interest in Research/Sponsored Programs, all investigators submitting protocols to the IRB for review must submit a conflict of interest disclosure statement. An investigator must disclose potential conflicts as outlined in this policy. Investigators must also update the protocol and/or disclosure anytime there is a significant change

A current Investigator of a federally funded grant/project, new IRB protocol or IRB member must do the following as a condition of Adelphi University’s continued support and administration of the grant/project, or IRB Protocol:

1. Complete FCOI training through the Office of Research and Sponsored Programs as follows:
   • Prior to: 
     • Engaging in research related to any federally-funded grant/project, including research funded by the Public Health Service (PHS), Investigators are required to complete FCOI training at the time of funding application. This will allow the researcher to be able to complete the SFI Disclosure form most accurately. This training is part of Adelphi University’s subscription to CitiProgram and can be accessed from their website. Once completed, you should send the Certificate to the Office of Research and Sponsored Programs.
     • Engaging in research using Human Subjects Research, Investigators are required to complete FCOI training within the Human Subjects Training Module within Citiprogram at the time of submission of the protocol. This will allow the researcher to be able to complete the Significant Financial Interest (SFI) .
     • Engaging in reviewing Human Subjects Research as part of the IRB, reviewers are required to complete FCOI training within the Human Subjects Training within Citiprogram. This will allow the IRB reviewer to be able to complete the SFI Disclosure form most accurately. This training is part of Adelphi University’s subscription to CitiProgram and can be accessed from their website. Once completed you should send the Certificate to the Office of Research and Sponsored Programs.
       • At least once every 4 years;
2. Immediately, if Adelphi revises its FCOI policy or procedures in any way that affects the requirements of Investigators if an Investigator is new to Adelphi, or if the Investigator is found to be not in compliance with the FCOI policy or management plan.
3. Complete a Significant Financial Interest Disclosure form for him/herself, his/her spouse, and his/her dependent children annually (by September 1st) during the period of the award, and within thirty (30) days of discovering or acquiring a new SFI, and submit it to the Office of Research and Sponsored Programs as described above.

University Responsibilities

The University is responsible for establishing an appropriate FCOI policy (this document), informing Investigators about FCOI, training Investigators in FCOI, monitoring FCOI compliance, maintaining FCOI records, and reporting FCOI to federal agencies whose funds are supporting Investigators’ research, as described in the following sections.

The person responsible for dissemination and implementation of this policy is labeled the “Institutional Official.” At Adelphi, this person is the Director of Adelphi’s Office of Research and Sponsored Programs (hereafter called the “Director of ORSP”). Adelphi’s Provost may designate another individual to fulfill this responsibility. The Institutional Official shall sign the Financial Interest Disclosure Form when the official is satisfied that there is no Conflict of Interest or that the Conflict of Interest has been appropriately managed, reduced, or eliminated.

The Director of ORSP will inform all Adelphi-affiliated individuals who seek to submit applications for federal funding of projects or research through Adelphi (i.e., new and potential Investigators) that to ensure compliance with federal regulations, Adelphi will require the new and/or potential Investigators, in order to receive Adelphi’s official approval and support for such applications for funding, to submit a completed SFI Disclosure form on behalf of him/herself, his/her spouse, and his/her dependent children to Adelphi’s Office of Research and Sponsored Programs.

• The Director of ORSP will also require new and/or potential Investigators to complete FCOI training through Adelphi’s Office of Research and Sponsored Programs before submission of the applications for funding.

The Director of ORSP will inform all Adelphi-affiliated Investigators with ongoing federal funding of research or projects (i.e. continuing Investigators) that, to ensure compliance with federal regulations, each Investigator must do the following in order to receive Adelphi’s continued support and administration of such ongoing federally-funded grants or projects:

• Complete FCOI training through the Office of Research and Sponsored Programs prior to engaging in federally-funded research, at least every four (4) years or more frequently in the University’s discretion, and immediately if Adelphi revises its FCOI policy relative to Investigators, if an Investigator is new to Adelphi, or if an Investigator is found not to be in compliance with the policy or management plan.
• Complete and submit to the Office of Research and Sponsored Programs a Significant Financial Interest Disclosure form by the time of submission of an application for federal funds for a research or project, at least annually during the period of an award, and within thirty (30) days of discovering or acquiring a new Significant Financial Interest.

The FCOI training provided through Adelphi’s Office of Research and Sponsored Programs includes information on Adelphi’s FCOI policy, on Investigator’s disclosure responsibilities, and on federal FCOI regulations.

SFI Review and FCOI Determination

• Review of SFI Disclosure forms, determination of FCOI, and additional actions described in Part 6.ii. below will take place in the following situations:
  • Before Adelphi spends federal funds for grants or projects awarded to an Adelphi-affiliated Investigator;
  • When a new Investigator participates in a research project;
  • When an existing Investigator discloses a new SFI;
  • If Adelphi identifies an SFI that was not disclosed in a timely manner by an Investigator or not previously reviewed by Adelphi.
• In the situations described in 6.i above, the Director of ORSP will do the following (for a situation described in 6.i.d, within sixty (60) days):
  • Review all Investigator SFI Disclosure forms in accordance with this policy and with federal regulations and guidelines.
  • Determine if any Investigator SFIs relate to federally-funded research.
  • Determine if an FCOI exists, i.e. a SFI that could directly and significantly affect the design, conduct or reporting of the federally-funded research or project.
  • If an FCOI does exist, develop and implement a management plan.
  • Monitor Investigator compliance with the management plan, including that of any subrecipient Investigators, until completion of the project.

Reporting to Federal Agencies

• The Director of ORSP is responsible for timely submission of proper FCOI reports to federal agencies such as NIH and NSF in accordance with their respective regulations.
• For PHS/NIH-funded projects at Adelphi, the Director of ORSP will submit to the NIH all initial, annual (i.e., ongoing) and revised FCOI reports including all the required reporting elements for Adelphi and any subrecipients.

Special Rules Applicable to PHS-Funded Research (i.e., NIH)

Any Research/Sponsored Program for which an Investigator is applying for PHS funding (“PHS-Funded Research”) must comply with the Adelphi University Policy on Conflicts of Interest in Research (the “Policy”), and must additionally comply with the Special Rules set forth in below.

Management and Reporting of Conflicts of Interest

• Public Disclosure of Policy: The Adelphi University Policy on Conflicts of Interest in Research/Sponsored Programs, including this Appendix A, is publicly available on the Adelphi Sponsored Programs website.
• Public Disclosure of Conflicts of Interest: Adelphi University will disclose any FCOI to all staff working on the grant. Adelphi University will also respond within five (5) calendar days to any request for information regarding Conflicts of Interest held by Key Personnel associated with any PHS-Funded Research. For any Conflict of Interest which has been disclosed and determined to exist in accordance with this Policy, Adelphi University’s response will include the following information: the Key Personnel’s name, title and role in the research project, name of the entity in which the SFI is held, the nature of the SFI, and the approximate dollar value of the SFI or a statement that the value cannot be readily determined through reference to public prices or other reasonable measures of fair market value. The response will note that the information provided is current as of the date of the correspondence and is subject to updates on an annual basis and within sixty (60) days of Adelphi University’s identification of a new Conflict of Interest, which should be requested subsequently by the requestor.
• Reporting to NIH:
  • Prior to Adelphi University ‘s expenditure of funds in connection with any PHS-Funded Research, Adelphi University will provide a report to the PHS Awarding Component regarding any Conflict of Interest of an Investigator which has been determined to exist in accordance with this policy (and has not been eliminated). The report will include information regarding the management plan which Adelphi University has implemented.
  • In the event that during the course of an ongoing PHS-Funded Research project, a new or newly-discovered SFI is disclosed, the Institutional Official shall within sixty (60) days determine whether a Conflict of Interest exists, and if so, the Institutional Official shall implement an interim management plan, subject to further institutional review. The new Conflict of Interest and management plan will be reported to the PHS Awarding Component.
  • Any report under (1) or (2) above will provide sufficient information for the PHS Awarding Component to understand the nature and extent of the financial conflict and to assess the appropriateness of Adelphi University’s management plan, including:
    • Project number and contact information;
    • The Investigator’s name, title and role in the research project, name of the entity in which the SFI is held, the nature of the SFI, and the approximate dollar value of the SFI or a statement that the value cannot be readily determined through reference to public prices or other reasonable measures of fair market value;
    • A description of how the financial interest relates to the Research and the basis for Adelphi University’s finding of a Conflict of Interest; and
    • A description of the key elements of the management plan, how it will safeguard objectivity, confirmation of the Investigator’s agreement to the management plan, how the plan will be monitored to ensure Investigator compliance, and other information as needed.
  • In the event that Adelphi University makes any report as provided above, Adelphi University will provide the PHS Awarding Component annual update reports throughout the period of the project, addressing the status of the Conflict of Interest, including whether it still exists and is being managed, and any changes to the management plan.
• Retrospective Review: In the event that a Conflict of Interest in connection with any PHS-Funded Research is not identified or managed in a timely manner including failure by the Investigator to disclose a Significant Financial Interest which is determined to be a Conflict of Interest, failure of the institution to review or manage the Conflict of Interest, or failure by the Investigator or Key Personnel to comply with a Conflict of Interest management plan, then the Institutional Official shall, within one hundred twenty (120) days of the institution’s determination of non-compliance, complete a retrospective review of the Investigator’s activities to determine whether any PHS-Funded Research, or portion thereof, conducted during the time period of the noncompliance, was biased in the design, conduct or reporting of such research.
  • The Institutional Official shall document the retrospective review, including:
    • Project title and number, and contact information;
    • The Investigator’s or Key Personnel’s name(s), title and role in the project, and name of the entity in which the Significant Financial Interest is held;
    • Reasons for the retrospective review and detailed methodology of the review process; and
    • Findings and conclusions of the review.
  • Based upon the results of the retrospective review, if appropriate, Adelphi University will update the previously submitted Conflicts of Interest report, specifying the actions which will be taken to manage the Conflict of Interest going forward. If bias is found, Adelphi University will promptly notify the PHS Awarding Component and submit a mitigation report, including the key elements documented in the retrospective review above and a description of the impact of the bias on the research project and Adelphi University plan of action or actions taken to eliminate or mitigate the effect of the bias. Adelphi University will update this report at least annually.

Maintenance of Records

The Director of ORSP is responsible for maintaining all FCOI-related records for at least three (3) years from the date that a final expenditures report for the project or research is submitted to the federal funding agency.

In the event that the Institutional Official determines that a Conflict of Interest exists for any Investigator, Key Personnel, and Integral Staff Members involved in proposed Research/Sponsored Programs, they shall advise the Investigator or Key Personnel on mechanisms designed to manage, reduce, or eliminate the Conflict of Interest. These may include, but are not limited to, the following:

• Public disclosure of the Significant Financial Interest whenever and as often as reasonably necessary to ensure objectivity of the Research/Sponsored Program.
• For research projects involving human subjects research, disclosure of the SFI directly to participants
• Monitoring of research by independent reviewers, such as independent peer review or audits of data.
• Modification of the research plan, such as using a double-blinded protocol where appropriate, ensuring that subjects are randomly selected or excluding the Investigator (Key Personnel or Integral Staff Members) from the portion of the research that may be affected by the Significant Financial Interest.
• Divestiture of the Significant Financial Interest.
• Severance of the relationships that create actual or potential Conflicts of Interest as a result of the Significant Financial Interest.
• Change of personnel or personnel responsibilities.
• Disqualification of personnel from participation in all or a portion of the funded activity dependent on the funding agency guidelines.

Enforcement Mechanisms and Remedies and Noncompliance

• Federal regulations require the University to take appropriate administrative actions to ensure compliance with this policy and with federal FCOI regulations. The Director of ORSP will report to the University’s Provost any real or potential FCOI and any instance of noncompliance with this policy or with an FCOI management plan relevant to a federally-funded project or research awarded to an Adelphi-affiliated Investigator. The Provost will render a decision regarding the specific actions that need to be taken. Adelphi maintains the right to impose sanctions consistent with the Collective Bargaining Agreement (CBA) between the University and the Adelphi chapter of the American Association of University Professors for failure to disclose FCOI, for failure to comply with this policy, or for failure to comply with an FCOI management plan relevant to a federally-funded project or research award. Such sanctions could include restrictions on future research submissions or other appropriate actions consistent with the CBA.
• If it is determined that this policy has not been properly complied with, including proper and timely SFI disclosure or proper and timely FCOI identification or management, the Director of ORSP will complete and document within one hundred twenty (120) days a retrospective review, which will be submitted to the Provost. Following a retrospective review, an update must be submitted to the relevant federal agency as in 7.D above.
  • The Committee on Objectivity in Research shall have authority to take any of the following actions upon a determination that any Investigator, faculty member, or administrator has violated this policy:
  • Issue a written reprimand that may be placed in the offender’s employment file.
  • Recommend that the offender be disciplined, up to and including termination.
  • Terminate the Research/Sponsored Program that is associated with the Conflict of Interest.
  • Bar the offender from Research/Sponsored Program activities for a specific period of time.
  • Report the violation to any sponsors, bodies, or individuals as may be required by federal regulations, laws or contracts.
• In the specific case that an NIH-funded clinical research project evaluating the safety or effectiveness of a drug, medical device, or treatment was designed, conducted or reported by an Investigator with an FCOI that was not managed or reported by Adelphi as required, the Investigator is required to disclose the FCOI in all public presentations of the research and is also required to request an addendum disclosing the FCOI to the relevant previously published articles or presentations.

Subrecipient Responsibilities

As noted above, Adelphi University’s FCOI also applies to subrecipients (subgrantee/subcontract). The subcontractor must complete AU’s online training and submit FCOI forms to the Director of the ORSP or the institution must certify in writing to the Director of the ORSP that it has its own FCOI policies in keeping with federal guidelines and that compliance with these FCOI policies has been obtained. Adelphi University will incorporate provisions into the written agreement with the subrecipient specifying which FCOI policy applies to the subrecipient’s Investigators. These documents will be kept by the Director of ORSP. Investigators who are affiliated with or employed by an institution of higher education, medical center, academic teaching hospital or research institute or other institution without a Financial Conflict of Interest Policy must complete Adelphi University’s training and submit Adelphi University’s FCOI forms. The subcontractor must disclose how it will comply with federally mandated FCOI regulations and provide the necessary documents to Adelphi University with the signed subcontract agreements before the expenditure and transfer of any funds.

Public Accessibility of FCOI Information

Adelphi University is committed to transparency in its research endeavors. To meet this goal, this FCOI policy will be posted on the Adelphi ORSP website. Also, any identified FCOI relevant to the institutional responsibilities of a federally-funded Investigator, Investigator’s spouse or dependent children, key members of the research team (as defined above under Investigator and subrecipient), will be posted on the ORSP website and updated on an annual basis. Information about newly identified FCOI will be updated on the ORSP website within sixty (60) days of identification. Information about identified FCOIs will remain available on the ORSP website for three (3) years from the most recent date that the information was updated. In addition, FCOIs will be made available upon written request within five (5) working days of receipt of that request. All reasonable attempts to provide updates of FCOIs will be made.

Committee on Objectivity in Research

Adelphi Office of Research and Sponsored Programs shall establish an ad hoc Committee on Objectivity in Research (if necessary) which may be advised by the Office of the Provost. In the event that the Institutional Official and the Investigator (or Key Personnel) do not agree on either the existence of a Conflict of Interest or on procedures that will ensure that a Conflict of Interest is managed, reduced, or eliminated, the Institutional Official shall refer the matter to the Committee on Objectivity in Research. The Committee shall make a decision after reviewing the research proposal and the Financial Interest Disclosure Form, and, if the Committee sees fit, after meeting with the Investigator (or Key Personnel). In the event that the Committee determines that a Conflict of Interest does not exist or has been appropriately managed, reduced, or eliminated, the Chair of the Committee shall indicate so in writing to the Institutional Official and Investigator (or Key Personnel).

Disclosure Requirements

Investigators, Key Personnel, and Integral Staff Members on grants are required to disclose, in accordance with the procedures set forth in the sections below, the following:

• Any Significant Financial Interest.
• Any Outside Activity which reasonably appears to be related to the Investigator’s Institutional Responsibilities.
• Any Travel sponsored or reimbursed by a foreign organization, regardless of the type of organization sponsoring the travel, and all other travel sponsored or reimbursed by any person or entity other than the following:
  • Adelphi University;
  • U.S. Federal, state or local governmental agencies;
  • U.S. Institutes of higher education;
  • U.S. Research institutes affiliated with Institutes of higher education; or
  • U.S. Academic teaching hospitals and medical centers.

Reimbursement from foreign universities and foreign research institutes affiliated with them require a travel disclosure. In connection with any such travel, the Investigator is required to disclose the purpose of the trip, the identity of the sponsor/organizer, the destination, and the duration.

Investigators are required to submit to the Institutional Official, in accordance with Sections of this policy, a completed and signed Adelphi University Financial Interest Disclosure Form (Please contact the Office of Research and Sponsored Programs to initiate a new COI form).

If you actively submit Research/Sponsored Programs grant proposals, you will be asked to complete the Financial Interest Disclosure Form annually so that ORSP has it on file for compliance purposes. You will then be asked to update it if anything has changed upon submission/award of a new grant or contract or IRB protocol.

The Financial Interest Disclosure Form must be submitted as follows:

• The Financial Interest Disclosure Form (if one isn’t already on file) must be submitted with any Research/Sponsored Programs proposal, and prior to the submission of any proposal to the sponsor, any Institutional Review Board, or any other outside entity.
• A new Form must be submitted annually thereafter during the pendency of the Research/Sponsored Programs project.
• A new Financial Interest Disclosure Form must be submitted within thirty (30) days of the Investigator’s discovering or acquiring a new Significant Financial Interest during the pendency of the Research/Sponsored Programs project.

Definitions

• A Financial Conflict of Interest (FCOI) exists when an Investigator’s Significant Financial Interest (SFI), as defined below, is related to a federally-funded research project and could directly and significantly affect the design, conduct or reporting of the research. For example, if an investigator owns a large amount of stock of a company whose medical device he or she is testing in a federally-funded clinical trial, the stock ownership creates a FCOI. The existence of a FCOI for an Adelphi University-affiliated Investigator will be determined by the Director of the Office of Research and Sponsored Programs at Adelphi University, in accordance with the guidelines given here and in consultation with the Provost or her designee.
• Significant Financial Interests (SFI) are defined as any of the following:
  • financial interests of the Investigator (and the Investigator’s spouse and dependent children) that reasonably appear to be related to an Investigator’s institutional responsibilities:
    • Compensation received from a publicly-traded entity in the twelve (12) months preceding disclosure, and/or any equity interest in such a publicly-traded entity, that together exceed five thousand dollars ($5,000). Compensation may include salary, and any payment for services not otherwise identified as salary, such as honoraria, consulting fees, and paid authorships.
    • Compensation received from a non-publicly-traded entity in the twelve (12) months preceding disclosure that exceeds five thousand dollars ($5,000), and any amount of equity held in a non-publicly traded entity.
    • Intellectual property rights and interests such as patents or copyrights, upon receipt of income related to such rights and interests.
  • Additionally, reimbursed or sponsored travel may represent a Significant Financial Interest and must be disclosed. Such travel is paid on behalf of the Investigator and its exact monetary value may not be readily available. This does not include travel that is reimbursed by a federal, state or local government agency, an institution of higher education, a medical center, etc. The information disclosed to Adelphi must include the purpose of the trip, the identity of the sponsor/organizer and of those affiliated with the Investigator who traveled, the destination, and the duration (see non-included travel defined below.) Based on this information, Adelphi may determine an approximate monetary value of the travel and the Director of the Office of Research and Sponsored Programs, in consultation with the Provost if necessary, will determine if a Significant Financial Interest exists.
    • Remuneration affected by the outcome of the Research/Sponsored Program—for example, compensation that is higher for a favorable outcome than for an unfavorable outcome;
    • Remuneration from the sponsor of the Research/Sponsored Program to the Investigator, or payments to Adelphi to support activities of the Investigator, which remuneration or payments are over and above the costs of conducting the current Research project;
    • Position as a director, officer, manager, employee or consultant to an entity with a Significant Financial Interest in the Research/Sponsored Program.
  • Significant Financial Interests do not include the following:
    • Salary, royalties and other remuneration from the University, where the Investigator is currently employed or otherwise appointed by the University, including intellectual property rights assigned to the University and agreements to share in royalties related to such rights.
    • Income from seminars, lectures, or teaching engagements and service on advisory committees or review panels for a federal, state or local government agency, an institution of higher education, medical center, or research institute affiliated with an institution of higher education.
    • Income from investment vehicles, such as mutual funds and retirement accounts, as long as the Investigator does not directly control the investment decisions made in these vehicles.
    • Travel that is reimbursed or sponsored by a federal, state, or local government agency, an institution of higher education, an academic teaching hospital, a medical center, or a research institute that is affiliated with an institution of higher education.
    • Compensation received from a publicly-traded entity in the previous 12 months, and/or any equity interest in such a publicly-traded entity, that together is $5,000 or less. Value shall be determined through reference to public prices or other reasonable measures of fair market value.
    • Compensation received from a non-publicly-traded entity in the previous 12 months that is $5,000 or less. Any equity interest in a non-publicly traded entity shall be considered a Significant Financial Interest.
• Investigator means the principal investigator or program director and any other person, regardless of title or position and including collaborators and consultants, who is responsible for the design, conduct or reporting of federally-funded research or proposed for such funding, “Investigator” does not include the spouse and dependent children of investigators, but as indicated above their Significant Financial Interests must also be disclosed.
• Research and Other Sponsored Projects means any internally or externally funded research, training or professional service project conducted at or under the auspices of Adelphi University. However, for this policy, research and other sponsored projects refers to federally funded programs only.
• Management Plan refers to the implementation of a plan to minimize the risk of bias in the design, conduct and reporting of the research, should a FCOI be determined.
• Subrecipients are other institutions or other personnel involved in an Adelphi federal grant or contract through an Adelphi specified subcontract. These other institutions or investigators are required to comply with Adelphi’s FCOI policy as described in this document.
• Equity Interest includes stocks, stock options and other ownership interests, but does not include income from investment vehicles, such as mutual funds and retirement accounts, provided the Investigator does not control the investment decisions made in these vehicles.
• Institutional Responsibilities means an Investigator’s professional responsibilities on behalf of Adelphi University, including teaching, Research/Sponsored Programs, administrative functions and committee memberships.
• Family means spouse and/or dependent children.
• Integral Staff Members means other staff members who are specifically named and listed on grants which may be research or non-research programmatic grants that have the ability to make purchase decisions and/or input transactions in financial systems like Unimarket on behalf of the research project or who are interacting with Human Subjects.
• Key Personnel also known as “Senior Personnel” means the Principal Investigator or Project Director and any other person identified as senior or key personnel in the grant application or in other institutional reports to the grantor.
• Adelphi University means Adelphi University and all of its schools, departments, centers, and affiliates.
• Public Health Service (PHS) means the Public Health Service of the U.S. Department of Health and Human Services, and any components of the PHS to which the authority involved may be delegated, including the National Institutes of Health (NIH).
• Remuneration means salary or any other payment for services, including consulting fees, honoraria and paid authorship.
• Research means a systematic investigation designed to develop or contribute to generalizable knowledge related broadly to public health, including behavioral and social science research. It encompasses both basic and applied research and product development.
• Sponsored Program includes but is not limited to any externally funded research, programmatic (i.e., STEP, CARES, HEERF, etc.), or scholarly activity that gets processed through ORSP.
• Outside Activity includes but is not limited to:
  • Employment;
  • Appointments;
  • Consulting;
  • Service on boards;
  • Business activities including managerial positions with domestic or foreign entities, whether or not remuneration is received; and
  • Financial interests, including but not limited to, stock, cash, and LLC interests in an entity that does business with Adelphi University.

Forms

• Conflict of Interest Disclosure Form
• IRB Manual

Related Information

• NIH FAQs
• NIH Requirements
• CitiProgram Online training

Document History

• Last Reviewed Date: July 2, 2025
• Last Revised Date: July 2, 2025
• Policy Origination Date: August 23, 2012

Who Approved This Policy

Provost and Cullen and Dykman