Research & Economic Development

Conflict of Interest

TTU Policy 735  (updated 11/15/2017)

  1. Purpose
    The purpose of this policy is to promote objectivity in research by establishing standards that provide a reasonable expectation that the design, conduct, and reporting of research, including those supported by grants, cooperative agreements, and contracts, will be free from bias resulting from Investigator Financial Conflicts of Interest. In particular, the Public Health Service (PHS) has promulgated regulations on “Promoting Objectivity in Research.” This Policy is premised on the Public Health Service (PHS) regulation 42 CFR Part 50.601 and the Code of Federal Regulations on Financial Conflict of Interest regarding research (45 CFR Part 94.1).
  2. Review
    This policy will be reviewed every three years or whenever circumstances require review, whichever is earlier, by the Associate Vice President for Research or his or her designee, with recommendations for revision presented to the Vice President for Research and Economic Development, Academic Council, Administrative Council, and University Assembly.
  3. Policy
    1. Tennessee Tech hereby adopts Code of Federal Regulations 42 CFR 50.601 et seq. and 45 CFR 94.1 on Conflict of Interest regarding research.
    2. Researchers must familiarize and comply with applicable policies and guidelines, including but not limited to:
      1. TTU Policy 132 (Conflict of Interest)
      2. TTU Policy 571 (Methods and Processes of Competitive Procurement)
      3. TTU Policy 732 (Intellectual Property)
      4. Section 510 of NSF Publication 95-26, the Grant Policy Manual
      5. T.C.A. § 8-31-102, Nepotism
      6. T.C.A. § 8-50-501, Disclosure Statements of Conflict of Interests by Certain Public Officials
      7. T.C.A. § 12-2-208, Purchase by Officer Unlawful—Penalty for Violation
      8. T.C.A. § 12-4-101, Personal Interest of Officers Prohibited
      9. T.C.A. § 12-4-102, Penalty for Unlawful Interest
      10. T.C.A. § 12-4-103, Bidding by State Employees Prohibited
      11. T.C.A. § 12-4-104, Penalty for Unlawful Transactions
      12. T.C.A. § 12-4-106, Prohibition Against Receiving Rebates, Gifts, Money or Anything of Value—Conflict of Interest
      13. Other Tennessee statutes pertinent to conflict of interest
      14. 37 CFR 401, Rights to Inventions Made by Nonprofit Organizations and Small Business Firms Under Government Grants, Contracts, and Cooperative Agreements
      15. Federal requirements in selecting sub-recipients and awarding procurement contracts (2 CFR 200.112)
    3. All researchers must comply with federal policies and regulations regarding conflict of interest in research, including, but not limited to, federal regulations 42 CFR 50.601 et seq. and 45 CFR 94.1 et seq.
    4. Before applying for grants and contracts, all researchers must take and pass the Responsible Conduct of Research CITI online training program, and follow TTU Policy 750 (Responsible Conduct of Research).
    5. Each researcher must make a disclosure of a potential or a real conflict of interest at the time of proposal submission by answering the questions contained on the Proposal Endorsement Form (PEF). Signatures on a completed PEF identifying no conflict of interest with the external organization shall suffice for negative disclosure.
    6. Disclosures must be indicated on the PEF and detailed by the respective investigator(s) in a separate statement that must be forwarded to the Office of Research at the time of submission of the proposal for funding consideration.
    7. If there is a change in the conflict of interest status of the investigator(s) prior to the time of award or after a contract is issued, the investigator(s) must report change(s) to the Office of Research in writing.
    8. Failure to comply with this or any other policy related to conflict of interest may  result in sanctions up to and including termination of employment.
  4. Interpretation The Vice President for Research and Economic Development or his/her designee has the final authority to interpret the terms of this policy.
  5. Citation of Authority for Policy T.C.A. § 49-8-203 (a)(1)(E); Title 37 CFR, Part 401; Section 510 of NSF Publication 95-26, the Grant Policy Manual; T.C.A. § 8-31-102; T.C.A. § 8-50-501; T.C.A. § 12-2-208; T.C.A. § 12-4-101; T.C.A. § 12-4-102; T.C.A. § 12-4-103; T.C.A. § 12-4-104; T.C.A. § 12-4-106; Tennessee Statutes pertinent to Conflict of Interest; 42 CFR 50.601 et seq.; 45 CFR 94.1 et seq.; 2 CFR 200.112
Approved by:
Administrative Council: November 15, 2017
Academic Council:  October 11, 2017
University Assembly: November 29, 2017