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 

A.     Tennessee Tech hereby adopts Code of Federal Regulations 42 CFR
        50.601 et seq. and 45 CFR 94.1 on Conflict of Interest regarding

B.     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
3.     TTU Policy 732 (Intellectual Property)
4.     Section 510 of NSF Publication 95-26, the Grant Policy
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)

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.

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).

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.

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.

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

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