Grants Management Handbook

Table of Contents

Part I. Getting Started

J. FINANCIAL DISCLOSURE TO AVOID CONFLICT OF INTEREST

Project director or investigator objectivity is extremely important for the responsible and ethical conduct of research and other Federally-funded project activities.  Federal grant projects are funded to contribute to the body of knowledge in the disciplines and to create and expand upon best practices.  Protecting the design, conduct, and reporting of externally funded projects from potential bias due to conflicting financial interests is critical.  Unfortunately, some researchers nationally have allowed conflicts of interest to bias their research findings.  For this reason, funding agencies such as the National Science Foundation and the National Institute of Health require principal investigators/project directors, and co-principal investigators to “disclose their significant financial interests and require institutions to maintain an appropriate written, enforced policy on conflict of interest” in keeping with the agency regulations.

Additional Conflicts of Interest Requirements.

The conflicts of interest disclosure requirements for Federal grants are in addition to the ones already applicable to MCCCD employees.  All MCCCD employees are expected to comply with Arizona Revised Statutes §38-503 prohibiting an employee who has, or whose relatives have, a financial or proprietary interest in a matter relating to MCCCD to disclose that interest and refrain from participating in any way in any vote, decision, contract, or purchase regarding that MCCCD matter. For more information on ARS §38-503 go to: http://www.maricopa.edu/legal/blc/coi_statutes.htm

Additionally, MCCCD’s All Employee Manual prohibits employees from participating in any way in the hiring or supervision of their relatives.  To comply with that law and policy, MCCCD employees are required, in July of each year, to acknowledge their understanding of those conflicts of interest restrictions and, if applicable, disclose their financial interests in a business, firm or organization that may have business dealing with MCCCD.  Employees are also asked to identify any relatives who also work in MCCCD.  Employees are required to electronically complete these acknowledgements, disclosures, and certifications annually through the Human Resource Management System (HRMS).  This information is reviewed by appropriate individuals in Business Services and Human Resources who take appropriate action when needed to address conflict of interest issues.

Requirements Specific to Certain Federal Agencies.

the National Science Foundation and the Health and Human Services agencies require all investigators to disclose to their institutions every significant conflict of interest prior to proposal submission. They also require updating, if necessary, prior to the expenditure of any funds for a new award. Other Federal agencies such as the U.S. Department of Education call for disclosure of financial interest to the institution prior to the expenditure of any grant funds.

Specific Financial Disclosure for Federally-funded Grants.

To ensure satisfactory compliance with the conflict of interest mandates under Federally-funded grants, the MCCCD Grants Development and Management Department has developed a Financial Disclosure for Avoiding Conflict of Interest in Federally Funded Projects form to more fully address Federal requirements for disclosure of financial interest.  As in the case of other MCCCD employee disclosures, it is accessed on-line through the HRMS system.  The District Grants needs to add you to the system so that it appears in your HRMS employee account.

The complete MCCCD Standards for Financial Disclosure to Avoid Conflict of Interest in Federally-Funded Projects is contained in Appendix I.

    • Who is required to complete the Financial Disclosure for Avoiding Conflict of Interest in Federally-Funded Projects?  All project directors, project investigators, including principal and co-investigators, and any other key personnel who are responsible for the design, conduct, or reporting of a research project or grant funded by Federal funding. This includes grants funded directly by Federal agencies as well as those that “pass through” other entities such as the State of Arizona, a university, or a municipality that are subgranted in whole or in part to us.  In addition, subgrantees, contractors, or collaborators of MCCCD’s under Federally-funded grants MCCCD receives must complete a report form or provide certification from their own organizations that they are in compliance with Federal policies regarding investigator significant financial disclosure.
    • What if I submit more than one grant proposal in the same year?  Do I need to do a separate form for each grant proposal?  Yes, you need to complete a new form for each grant proposal.
    • How often does this form ned to be updated? This information needs to be updated annually by October 1st of each year and at any time that there is a reportable change in your financial interests that could potentially be considered a conflict of interest with the grant.
    • What do I do if I am partnering with a university on one of their NSF grants? If you are serving as a co-principal investigator on another institution's NSF grant, you still need to complete MCCCD's Financial Disclosure to Avoid Conflict of Interest in Federally Funded Programs form. The university will require MCCCD certification of conflict of interest compliance through documents such as a subrecipient agreement or a subcontract. So, the MCCCD form needs to be completed before these documents can be signed by our Legal Services Department.

     

     

     

     

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