Frequently Asked Questions

Conflict of interest training is designed to help you identify, avoid and, if necessary, disclose conflicts of interest. Faculty and staff are encouraged to engage in appropriate outside relationships, participate in sponsored research and consult widely. These activities benefit not only the participants but also the University itself and the larger public. Because some relationships and activities might carry potential conflicts of interest for Clemson faculty and staff, conflict of interest training helps you to determine what must be disclosed, reviewed and managed in order to avoid risk for you and the University.

Your conflict of interest training should take approximately 15 minutes.

It depends on whether you have any interests to disclose.  If you have nothing to disclose, the disclosure form takes approximately 5 minutes to complete and certify.

The form is reviewed for completeness and accuracy, and the COI administrator will determine whether a potential conflict of interest exists and if further review is required. Further review will include members of the PHS-COI Committee and, if a conflict of interest exists, a COI management plan will be created. This will involve your department chair or supervisor and the associate dean for research.

Confirming that you do not have any potential conflicts by completing a disclosure form is part of the University's conflict of interest oversight process and key to demonstrating the University's management of potential conflicts. It is also the responsibility of the Institution rather than individuals to determine whether a conflict of interest exists between your research and financial interests.

Anyone required to complete a disclosure form must do so annually, within 30 days of discovering or acquiring a new significant financial interest, and when changes occur in the circumstances of a financial interest or outside activity what was previously disclosed.

The PHS-COI Committee is responsible for identifying conflicts of interest with any PHS funded proposals.  The PHS-COI Committee determines that a conflict of interest exists if there is a reasonable expectation that an investigator’s significant financial interest could influence the conduct of Clemson University research.

This situation does not typically represent a conflict of interest. Stocks held with publically traded entities as part of an overall investment portfolio (401k) do not represent a conflict of interest.

The following are examples that typically do not pose a conflict of interest between the employee and the University:

  • A staff member works as an administrative assistant at the University and plays in a band that performs on the weekends at local hangouts.
  • A faculty member, on occasion, visits a corporation in which his wife his employed. His visits are related to student advising. His wife works in the purchasing department for the corporation, and the two do not overlap in any capacity.
  • The wife of a faculty member serves as an external reviewer for a federal funding agency in his field of expertise.
  • An employee’s family owns a restaurant, and the restaurant has been approached about catering upcoming off-campus events.

Potentially yes. You should report your activities and have the Conflict of Interest Committee review your specific situation.

Examples of situations that have the potential to be a conflict:

  • Department Chair Y wrote a book prior to their employment at CU. Faculty members within the department may feel pressure to use the book for their classes since it is relevant to their teaching topics.
  • Joe manages a lab on campus, and the lab has recently flooded. His wife works for a company that specializes in lab clean ups, and is registered as a Clemson University vendor. 
  • Sam owns a consulting company on the side. He, in his university capacity, recently received a “gift” from a company that regularly uses his consulting company.
  • An employee owns a lawn care business, and would like to become a vendor for the University.

Yes. You should report your activities immediately so that the Conflict of Interest Committee can assist in creating a conflict of interest management plan.

Examples of situations that result in a conflict of interest:

  • Department Chair A was recently promoted from within the department, and now she supervises her spouse.
  • A purchasing agent for the University wants to hire his brother-in-law to provide consulting services to the department in which he works.
  • A staff member owns a business that specializes in a product that is needed for the department in which she works on campus. She wants the department to purchase the products directly from her.
  • An employee’s spouse is involved in the same sponsored project, and the employee is the lead Principal Investigator.

All investigators listed on the proposal must complete a disclosure form prior to submission of a proposal for research funding. Once your disclosure is made, the submission of a proposal will not be delayed for conflict of interest reasons. If a disclosure is determined to relate to the research within the proposal, awarded funds may be held until the potential conflict is managed.

Prior to the expenditure of research funds where the research relates to a conflict of interest, the conflict must be managed. An award that relates to a conflict of interest can be accepted, but may be held until the conflict of interest is managed. Each conflict of interest has unique circumstances and the expenditure of funds will be dependent on the nature of the conflict and the nature of the award.

Once a conflict of interest has been identified, the conflict of interest administrator and the Conflict of Interest Committee will consult with you, your department chair or supervisor and the associate dean for research. Together the group will design a plan of conditions or restrictions to manage the conflict of interest. You will have the opportunity to review and accept this plan. This is called a COI management plan.

Clemson University must make certain information available concerning identified financial conflicts of interest held by senior/key personnel via a publicly accessible website or by a written response to any requestor within five business days of a request. PHS defines “senior/key personnel” as the project director or Principal Investigator and any other person identified as senior/key personnel by the Institution in the grant application, progress report, or any other report submitted to the PHS by the institution. At a minimum, Clemson University must provide the following information:

  • Investigator's name;
  • Investigator's title and role with respect to the research project;
  • Name of the entity in which the significant financial interest is held;
  • Nature of the significant financial interest; and
  • Approximate dollar value of the significant financial interest (dollar ranges are permissible: $0-$4,999; $5,000-$9,999; $10,000-$19,999; amounts between $20,000-$100,000 by increments of $20,000; amounts above $100,000 by increments of $50,000) or a statement that the interest is one whose value cannot be readily determined through reference to public prices or other reasonable measures of fair market value.

Since outside activities and financial interests change, federal regulations and University policy require that disclosure be made on an annual basis.

To aid in facilitating easy and efficient COI disclosure, the online system has several key features:

  • The expiration date on your form is a year from your most recent submission. If you update your form mid-way through the year, your expiration date is reset.
  • 30 days before your form expires, you will receive a notification that your form is expiring soon.
  • Previous disclosures will automatically be copied to your next draft within InfoEd.

Visit TigerTraining.clemson.edu to access your conflict of interest training.

How do I complete my disclosure?

  1. Log in to InfoEd using your Clemson University username and password.
  2. Select "External Interests" on the left navigation panel.
  3. Select "New" in the drop down panel.
  4. Select "Edit/Submit Disclosure".

A member of the University community – officer, administrator, faculty, staff, student or trainee – may be deemed to have a conflict of interest when he or she or any of that person’s family possesses a personal or financial interest related to an activity that involves his or her University responsibilities. This includes all full-time, part-time, temporary, and contract employees and others acting on Clemson’s behalf in the performance of the teaching, research, public service, administration and business operations of the University.

Any principal investigator or any member of the key personnel on any project funded by the U.S. Public Health Service, e.g. NIH and CDC, and any principal investigator or member of the key personnel of any project that is a sub-award or subcontract under another entity’s PHS-funded project must report sponsored travel. Key personnel include individuals who are directly appointed and charged to the project and those whose effort is cost-shared. Individuals who anticipate receiving PHS-funded awards should also report sponsored travel that will occur in the next 12 months or that is related in any way to the proposed PHS-funded project.

42 CFR Part 50 Subpart F requires reporting sponsored travel related to a PHS-funded Investigator’s institutional responsibilities. 42 CFR Part 50 Subpart F, which promotes objectivity in research by establishing standards that provide a reasonable expectation that the design, conduct, and reporting of research funded under Public Health Service (PHS) grants or cooperative agreements will be free from bias resulting from Investigator financial conflicts of interest. [Commonly known as the Financial Conflict of Interest (FCOI) regulations].

The FCOI regulations require all PHS funded investigators to “disclose the occurrence of any reimbursed or sponsored travel (i.e., that which is paid on behalf of the Investigator and not reimbursed to the Investigator so that the exact monetary value may not be readily available), related to their institutional responsibilities…” 42 CFR §50.603.

The following MUST be reported. This is not an exhaustive list, and investigators should report any reimbursed or sponsored travel that would reasonably be interpreted to be related to their PHS-funded research. All travel that is reimbursed or paid directly by:

  • Any person or entity for whom you are serving as a consultant except other universities and government agencies as described below
  • The sponsor of your research except other universities and government agencies as described below
  • Any vendor, prime contractor, or any sponsor of a sub-award or subcontract except other universities and government agencies as described below,
  • Any for-profit company or non-profit organization, other than another university as described below, for speaking or participation in meetings, conferences, proceedings, etc.,
  • Any person or entity for whom you are serving as an expert witness
  • Any entity in which you have a personal financial interest such as a start-up company, a licensee of intellectual property that you invented or created, consulting company or other business

Sponsored travel for participation in many scholarly activities such as serving as a grant reviewer for a government agency, or serving on a government task force or panel does not need to be reported. The sponsored travel that DOES NOT need to be reported includes travel that is reimbursed or paid directly by:

  • A federal, state, or local government agency
  • An institution of higher education as defined at 20 U.S.C. 1001(a)
  • An academic teaching hospital, a medical center, or a research institute that is affiliated with an institution of higher education
  • Clemson University
  • Any person or entity your service on national academies panels, committees, roundtables, task forces or membership meetings
  • Non-profit organizations in which Clemson University is a member institution and for which you are serving as a member of its governing board, a panel or a task force where such service has been approved by the Institute

No, you are not required to take this training during your approved extended leave. Upon your return to Clemson, you will be provided alerts of training and a due date for any required training. These alerts are provided through the university’s training management system, Tiger Training.

Report it to the ethics/safety Hotline.
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