Conflict of Interest

As a Carnegie R2 institution, Hofstra has a series of written policies and procedures to ensure that research is designed, conducted, and reported without bias from an investigator’s personal financial interests.  This page outlines required procedures applicable for implementing the policies in order to certify proposal submissions and awards for sponsored programs.

Hofstra University outlines its policies and procedures for managing conflict of interest in sponsored projects in FPS#33A, Financial Conflict of Interest (FCOI) Policy in Relation to Sponsored Projects and the University’s Conflict of Interest Policy, the latter of which applies to any investigator participating in sponsored research. Per FPS#33a, investigators are those “responsible for the design, conduct, or reporting of research, educational or other activities funded or proposed for funding by an external sponsor.”

Additional relevant policies include:

• FPS #8: Outside Employment for Faculty
• FPS #33: Conflict of Interest
• FPS#41: Policy for Dealing with and Reporting Possible Misconduct in Research

Per FPS33a, each investigator is required to complete the Internal Review Form and the Significant Financial Interest Disclosure Form and submit it, along with any necessary documentation at least two weeks in advance of a proposal submission.

If potential or perceived conflicts arise on required Significant Financial Interests forms, Dr. Colleen Fitzgerald, Senior Vice Provost for Research and Creative Activities, serves as the conflicts official for Hofstra investigators.

Mandatory training in Conflict of Interest is required at least every four years for investigators submitting proposals and participating in sponsored research.  Hofstra University maintains a subscription to CITI Program to satisfy Conflict of Interest training.  Investigators should register with CITI using their Hofstra email account and should provide the certificate as a record of the training to provide to ORSP as requested upon submissions.

Additional retraining is required immediately under the following circumstances:

• University FCOI policies change in a manner that affects investigator requirements
• An investigator is new to the University
• The University finds an investigator noncompliant with this policy or an FCOI management plan.

Financial Conflict of Interest (FCOI) regulations exist to protect scientific integrity and public trust in taxpayer-funded research. A Financial Conflict of Interest (FCOI) means there is a Significant Financial Interest (SFI) that could directly and appreciably affect the design, conduct or reporting of sponsored research.  

ORSP uses this form (for investigators to disclose potential conflicts of interest (Part I) and if applicable, to document significant financial interests (Part II).

Holding an SFI does not mean a conflict of interest exists. An SFI constitutes a financial interest that necessitates a disclosure. It becomes a Financial Conflict of Interest (FCOI) only if the institution’s reviewing official determines that the SFI could directly and significantly affect the design, conduct, or reporting of the research. Upon submission, disclosures are reviewed to determine if the SFI disclosed is related to sponsored research. If a determination is made that there is an FCOI as defined by the policy, a conflict of interest management plan must be finalized before the expenditure of any funds under a sponsored project.

In this manner, the University ensures that FCOIs are managed, that is, appropriate action is taken to address an FCOI, which can include reducing or eliminating the FCOI, to ensure, to the extent possible, that the design, conduct, and reporting of research will be free from bias. 

A research conflict of interest management plan (link here) has been developed to enable the University to detail steps taken to manage, reduce, or eliminate the FCOI presented by a Significant Financial Interest. Approved management plans have oversight to monitor compliance with the agreed upon terms.  Generally speaking, there are a range of steps that may be taken in a management plan (i.e., including but not limited to disclosure of FCOIs to students, collaborators and on publications; review of research protocols by independent reviewers; change of personnel or personnel responsibilities, or disqualification of personnel, divestiture of Significant Financial Interests, etc.).

Investigators should keep their own records and are responsible for staying in compliance with policies and procedures. Currently, forms are electronic PDFs held in ORSP files for the COI training certificates through CITI Program, and the signed copies of COI and SFI disclosures. Longer-term, the University will be adopting the Conflict of Interest module in the compliance suite of the new electronic research administration platform, Cayuse, with an expected implementation later in 2027. This will bring greater integration of training and protocol documentation with each other and with sponsored awards. Stay up to date on our Cayuse implementation via the Cayuse Info Hub (sso required).