CSUSB/UEC Financial Conflict of Interest Policy

California State University, San Bernardino

Conflict of Interest Policy for External Sponsored Programs

CSUSB and the University Enterprises Corporation at CSUSB (UEC) encourage the involvement, collaboration, and partnership of academic researchers and educators with public and private sector grants, contracts, ventures, and entrepreneurial activities. However, such involvements create a risk of conflict between the private interests of individuals, the companies with which they are involved, and the public interest. CSUSB and the UEC have adopted policies that regulate potential conflicts of interest among faculty and staff members employed on grants and contracts as required by federal, state, CSU, and CSUSB laws and policies. If a real or potential conflict is disclosed, it will be confidentially reviewed and a determination made whether the conflict requires the development of a resolution plan to address the conflicts.

Investigators of all externally sponsored programs must follow this policy.  They policy covers three specific situations:

1) NIH/PHS grants. Investigators must complete a Conflict of Interest training program (CITI Training Site). You will need to register first and then you will be able to log-on to the CITI Website. Please complete the Significant Conflict of Interest Disclosure Form prior to submission of an NIH/PHS grant proposal.  Other aspects of the NIH/PHS requirements are found in the following detailed CSUSB NIH/PHS Conflict of Interest Policy (link here). Please note the CITI site has several types of training modules including human subjects research and animals subjects research. One you register you will see an option to complete the finanical conflict of interest training. Additional instructions are noted on the IRB website (see CITI Registration Step by Step Guide on IRB Website where access to the training is located).

  • CITI Website
    • Conflict of Interest (FCOI), Animal Subjects (IACUC), and Human Subjects (IRB) Training Programs

2) Non-governmental grants.  Investigators who are awarded grants from non-governmental sponsors (e.g., foundations and corporations, these are typically given grant numbers starting with the prefix “NG-“) must complete a the Chancellor’s Office Conflict of Interest training program and complete the Form 700U.  If you have a non-governmental award, Human Resources will contact you regarding the training and the form.

3) All other sponsored programs.  All investigators not covered by the above situations must complete the Significant Conflict of Interest Disclosure Form at the time of award.