Office of Sponsored Programs

Conflict of Interest

TTU Policy 735 (updated 1/1/2018)

I.     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). 

II.     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, Administrative Council, Academic Council, and University Assembly. 

III.     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. C.     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. D.     Before applying for grants and contracts, all researchers must take
           and pass the Responsible Conduct of Research CITI online training
           program, found on the CITI Training page of Research
           & Economic Development website under Research Compliance,
           and follow TTU Policy 750 (Responsible Conduct of Research).
5. E.     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, which can be found on
           the Forms page of Research & Economic
           Development website, identifying no conflict of interest with the
           external organization shall suffice for negative disclosure.
6. F.      Disclosures must be indicated on the PEF and detailed by the
           respective investigator(s) in a separate statement that must be
           forwarded to Research & Economic Development at the time of submission of the proposal for funding consideration.
7. G.     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
           Research & Economic Development in writing.
   H.     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. 

IV.     Interpretation
 
The Vice President for Research and Economic Development or his/her designee has the final authority to interpret the terms of this policy. 

V.     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:    11/15/17; 2/25/15 

Academic Council:            10/11/17 

University Assembly:        11/29/17; 4/22/15