Chapter V Contents
500 Background V-1
501 Prospective Grantee Organization and Management Data V-1
501.1 General V-1
501.2 Definitions V-1
501.3 Required Information V-2
510 Conflict of Interests Policies V-2
520 Financial Management Systems Standards V-4
530 Procurement Standards V-4
540 Property Management Standards V-4
541 Background V-4
542 Title to Equipment V-4
542.1 Title to Equipment - Non-Profit Organizations V-4
542.2 Title to Equipment - Commercial Organizations V-4
543 Conditions for Acquisition and Use of Equipment V-4
544 Use of NSF-Supported Research Instrumentation and Facilities Guidelines V-5
545 Property Management Standards When Title Retained by NSF V-5
546 Excess Government Personal Property V-5
546.1 Policy V-5
546.2 Eligibility V-5
546.3 Procedures V-6
546.4 Visiting Holding Agency Facilities V-6
546.5 Dollar Limitation V-7
546.6 Restrictions V-7
546.7 Costs V-7
546.8 Title V-7
546.9 Accountability and Recordkeeping V-8
This chapter discusses various grantee management standards with which recipients are expected to comply. It consists of the following topics:
510 CONFLICT OF INTEREST POLICIES
520 FINANCIAL MANAGEMENT SYSTEMS STANDARDS
530 PROCUREMENT STANDARDS
540 PROPERTY MANAGEMENT STANDARDS
a. NSF requires prospective grantees to furnish, upon request by DGA, basic organization and management information to assist the NSF Grants Officer in assessing their financial and managerial responsibility. GPM 501 describes NSF requirements for the furnishing of organization and management information.
b. NSF encourages the increased involvement of academic researchers and educators with industry and private entrepreneurial ventures, but recognizes that such interactions carry with them an increased risk of conflict of interests. GPM 510 contains NSF's policy on conflict of interest.
c. OMB Circular A-110 prescribes three sets of standards for academic and other non-profit recipients of Federal grants. These govern financial management systems, procurement policies and procedures and property management. GPM sections 520-540 implement the OMB standards, and extend their applicability to all types of recipients of NSF grants, including commercial firms.
501 Prospective Grantee Organization and Management Data
Each proposing organization that has not received an NSF grant within the previous two years should be prepared to submit basic organization and management information and certifications, when requested, to DGA.
a. COLLEGE OR UNIVERSITY is a public or private institution of post secondary education which, if a U.S. college or university, is listed in the current edition of the Directory of Post-secondary Institutions, published in two volumes by the Center for Education Statistics, U.S. Department of Education, and for sale by the Superintendent of Documents, U.S. GPO.
b. HOSPITAL is an organization which is a member of the American Hospital Association, whether or not it is subject to the control of Federal, State or local governments.
c. OTHER NON-PROFIT ORGANIZATION is any corporation, trust, association, cooperative or other organization which:
1. is operated primarily for scientific, educational, service, charitable or similar purposes in the public interest;
2. is not organized primarily for profit; and
3. uses all income exceeding costs to maintain, improve and/or expand its operations.
For this purpose the term "non-profit organization" excludes colleges and universities, hospitals and State, local and Indian tribal governments. An organization which has tax exemption as a non-profit organization from the U.S. Internal Revenue Service (IRS) shall be considered to have met the criteria of this definition.
d. SMALL BUSINESS is a concern, including its affiliates, which is independently owned and operated, is not a "non-profit organization," is not dominant in the field of operation in which it is proposing, and can further qualify under the criteria concerning the number of employees, average annual receipts or other criteria, currently prescribed by the Small Business Administration (SBA) for the purpose (e.g., eligibility for SBIR program) for which the small business classification is claimed. (See 13 CFR §121.)
e. OTHER COMMERCIAL FIRM is any corporation, trust or other organization which is organized primarily for profit and does not meet the SBA criteria for being a "small business."
f. STATE is any of the States of the United States, the District of Columbia, the Commonwealth of Puerto Rico, any territory or possession of the United States or any agency or instrumentality of a State exclusive of State institutions of higher education and hospitals.
g. LOCAL GOVERNMENT is a unit of government including a county, municipality, city, town, township, local public authority, school district, special district, intrastate district, council of governments, other regional or interstate government entity, Indian tribal government or any agency or instrumentality of a local government exclusive of institutions of higher education and hospitals.
501.3 Required Information
Upon request, the following information will be submitted to DGA.
a. Organization Name. The commonly used name of the organization, together with the legal (registered) name, if different, and mailing address.
b. Organization Type. The appropriate organizational type defined in GPM 501.2, or, if some other type, so indicate. If a U.S. college or university, show the Federal Interagency Committee on Education code, and category of control or affiliation as shown in the most recent Directory of Post-secondary Institutions.
c. Federal Employer Identification Number. The employer identification number as assigned by the IRS (applicable to U.S. organizations only).
d. Congressional District. The congressional district in which the organization is located (applicable to U.S. organizations only).
e. Organizational Affiliations. The relationship of the organization to any parent organization or to subsidiaries or other affiliates. If the organization is a successor in interest to a predecessor or if changes in organizational affiliation are anticipated, describe briefly.
f. Statement of Purposes and Powers. An official or published statement of the major purposes of the organization and the powers which have been granted to it to enter into contractual relationships and/or to accept grants (e.g., articles of incorporation, terms of reference or by-laws).
g. Key Officials. The name, title, address and telephone number of the following officials and their alternates (if applicable):
1. Chief Executive Officer. (NSF grant letters normally are addressed to the Chief Executive Officer unless another appropriate addressee, such as the Authorized Organizational Representative, is so designated.);
2. Authorized Organizational Representative; and
3. Business Officer.
h. Affiliations of Key Officials. If the organization is other than a college or university, a State or local government or an international organization, indicate whether or not each official listed in g, above, is affiliated with any international, Federal, State or local agency, or with any college or university. If so, describe such affiliation. NSF reserves the right to consult with such affiliated organizations.
i. Federal Grants. A representative listing of current or recent Federal grants to the organization indicating agency, grant number, grant amount and title of project.
j. Indirect Cost Agreement. A copy of the most recent indirect cost agreement negotiated between the organization and some Federal agency or, if lacking such an agreement, an indirect cost rate proposal. (See GPM 632.1, "Basic Policy," and 634.2, "NSF Calculation of Indirect Cost Amount.")
k. Grantee Standards. A statement that the organization will or will not comply with the following standards:
1. Financial Management Systems (GPM 520);
2. Procurement Standards (GPM 530); and
3. Property Management Standards (GPM 540).
l. Other. If other than a college or university, or a State or local government, also submit the following:
1. a certified statement of financial condition covering at least the preceding two years; and
2. bank or other references.
510 CONFLICT OF INTEREST POLICIES
The following policies on conflict of interest are effective October 1, 1995.
a. NSF requires each grantee institution3 employing more than fifty persons to maintain an appropriate written and enforced policy on conflict of interest. Guidance for such policies has been issued by university associations and scientific societies.4
b. An institutional conflict of interest policy should require that each investigator disclose to a responsible representative of the institution all significant financial interests of the investigator (including those of the investigator's spouse and dependent children) (i) that would reasonably appear to be affected by the research or educational activities funded or proposed for funding by NSF; or (ii) in entities whose financial interests would reasonably appear to be affected by such activities.
The term "investigator" means the principal investigator, co-principal investigators, and any other person at the institution who is responsible for the design, conduct, or reporting of research or educational activities funded or proposed for funding by NSF.
The term "significant financial interest" means anything of monetary value, including, but not limited to, salary or other payments for services (e.g., consulting fees or honoraria); equity interest (e.g., stocks, stock options or other ownership interests); and intellectual property rights (e.g., patents, copyrights and royalties from such rights).
The term does not include:
1. salary, royalties or other remuneration from the applicant institution;
2. any ownership interests in the institution, if the institution is an applicant under the Small Business Innovation Research Program or Small Business Technology Transfer Program;
3. income from seminars, lectures, or teaching engagements sponsored by public or non-profit entities;
4. income from service on advisory committees or review panels for public or nonprofit entities;
5. an equity interest that, when aggregated for the investigator and the investigator's spouse and dependent children, meets both of the following tests: does not exceed $10,000 in value as determined through reference to public prices or other reasonable measures of fair market value, and does not representor represent more than a 5% ownership interest in any single entity; or
6. salary, royalties or other payments that, when aggregated for the investigator and the investigator's spouse and dependent children, are not expected to exceed $10,000 during the twelve month period.
c. An institutional policy must ensure that investigators have provided all required financial disclosures at the time the proposal is submitted to NSF. It must also require that those financial disclosures are updated during the period of the award, either on an annual basis, or as new reportable significant financial interests are obtained.
d. An institutional policy must designate one or more persons to review financial disclosures, determine whether a conflict of interest exists, and determine what conditions or restrictions, if any, should be imposed by the institution to manage, reduce or eliminate such conflict of interest. A conflict of interest exists when the reviewer(s) reasonably determines that a significant financial interest could directly and significantly affect the design, conduct, or reporting of NSF-funded research or educational activities.
Examples of conditions or restrictions that might be imposed to manage, reduce or eliminate conflicts of interest include, but are not limited to:
1. public disclosure of significant financial interests;
2. monitoring of research by independent reviewers;
3. modification of the research plan;
4. disqualification from participation in the portion of the NSF-funded research that would be affected by significant financial interests;
5. divestiture of significant financial interests; or
6. severance of relationships that create conflicts.
If the reviewer(s) determines that imposing conditions or restrictions would be either ineffective or inequitable, and that the potential negative impacts that may arise from a significant financial interest are outweighed by interests of scientific progress, technology transfer, or the public health and welfare, then the reviewer(s) may allow the research to go forward without imposing such conditions or restrictions.
e. The institutional policy must include adequate enforcement mechanisms, and provide for sanctions where appropriate.
f. The institutional policy must include arrangements for keeping NSF's Office of the General Counsel appropriately informed if the institution finds that it is unable to satisfactorily manage a conflict of interest.
g. Institutions must maintain records of all financial disclosures and of all actions taken to resolve conflicts of interest for at least three years beyond the termination or completion of the grant to which they relate, or until the resolution of any NSF action involving those records, whichever is longer.
520 FINANCIAL MANAGEMENT SYSTEMS STANDARDS
NSF grantees are required to have financial management systems which meet the requirements of Section .21 of OMB Circular A-110.
530 PROCUREMENT STANDARDS
NSF grantees shall adhere to the requirements of Sections .41 through .48 of OMB Circular A-110 which prescribe standards for use by recipients in establishing procedures for the procurement of supplies and other expendable property, equipment, real property and other services with Federal funds.
540 PROPERTY MANAGEMENT STANDARDS
a. Sections .31 through .37 of OMB Circular A-110 prescribe standards governing the management and disposition of property furnished by the Federal government or whose cost was charged to a project supported by a Federal grant.
b. In the rare instances where NSF grants might involve the acquisition of real property and unless otherwise specified in the grant document, the real property standards of OMB Circular A-110 are applicable to such NSF grants.
c. NSF implementation of the OMB standards on intellectual property is contained in GPM 730, "Intellectual Property."
d. Title to materials developed and supplies purchased under an NSF grant will vest in the grantee.
e. Section .33(b) of OMB Circular A-110 contains a special category of "exempt property." Under that provision, any Federal agency which has statutory authority (such as NSF) may vest title in an institution of higher education, hospital or other non-profit organization without further obligation to the Federal Government and under conditions the agency considers appropriate.
542 Title to Equipment
542.1 Title to Equipment - Non-Profit Organizations
a. Normal Situations. Unless otherwise specified in the grant document, title to equipment purchased or fabricated with NSF grant funds by a college or university or other non-profit organization will vest in the grantee organization upon acquisition. Such equipment is considered "exempt property" (see GPM 541, "Background") and subject to the conditions of GPM 543, "Conditions for Acquisition and Use of Equipment."
b. Special Situations. In special situations the grant document may require that title to equipment purchased, acquired or fabricated by the grantee with NSF funds pass directly to the government from the vendor.
c. Excess Government Personal Property. See GPM 546.
542.2 Title to Equipment - Commercial Organizations
Unless otherwise specified in the grant document, title to equipment purchased or fabricated with NSF grant funds by a small business or other commercial firm (as defined in GPM 501.2) will vest in the government. Such equipment will be acquired and used in accordance with GPM 543, "Conditions for Acquisition and Use of Equipment," and managed in accordance with GPM 545, "Property Management Standards When Title Retained by NSF."
543 Conditions for Acquisition and Use of Equipment
a. Grantee Assurance. The grantee will assure that for each purchase of equipment, it is:
1. necessary for the research or activity supported by the grant;
2. not otherwise reasonably available and accessible;
3. of the type normally charged as a direct cost to sponsored agreements; and
4. acquired in accordance with organizational practice.
b. General Purpose Equipment. Expenditures for general purpose equipment (see GPM 612.2c, "Definitions") are unallowable unless the equipment is primarily or exclusively used in the actual conduct of research.
c. Equipment Usage. The equipment must remain in use for the specific project for which it was obtained in accordance with OMB Circular Section .34c., unless the provision in Section .34e. applies.
d. Equipment Sharing. The equipment must be shared on other projects or programs in accordance with OMB Circular A-110 Section .34d.
e. Property Management Standards. The grantee shall maintain a property management system which, at a minimum, meets the requirements of OMB Circular A-110 Section .34f.
f. Competition. Grantees shall not use equipment acquired with Federal funds to provide services to non-Federal outside organizations for a fee that is less than private companies charge for equivalent services, unless specifically authorized by statute, for as long as the Federal Government retains an interest in the equipment.
g. Right to Transfer Title.
1. NSF may identify items of equipment having a unit acquisition cost of $5,000 or more where NSF reserves the right to transfer the title to the Federal government or to a third party named by the Federal government.
2. In such cases where NSF elects to transfer the title, disposition instructions will be issued no later than 120 calendar days after the expiration date of the NSF-supported project for which it was acquired.
544 Use of NSF-Supported Research Instrumentation and Facilities Guidelines
In March 1983, the National Science Board adopted Principles Related to NSF-Supported Research Instrumentation and Facilities (Important Notice 91) and approved guidelines to aid grantees in their implementation. (See Exhibit V-1.) Those principles and guidelines address the use of NSF-supported research instrumentation and facilities in providing services for a fee in direct competition with private companies that provide equivalent services. Grantees should implement those principles and guidelines in a reasonable manner and provide fair and adequate consideration of any complaints about use of instrumentation and facilities.
545 Property Management Standards When Title Retained by NSF
In the event that title to equipment or property is vested in the Federal Government, such property shall be marked, tagged or segregated in such a manner as to indicate clearly its ownership by the government. Unless otherwise provided in the grant instrument, such government property shall be used only for the performance of the project. The grantee shall submit an annual inventory report by NSF grant number of such property having an original acquisition cost of $5,000 or more, to the NSF Property Administrator, Division of Administrative Services (DAS). A physical inventory of Government-Owned Equipment (GOE) shall be conducted every two years pursuant to Section .34f of OMB Circular A-110. Upon expiration of the grant, the grantee shall report the property to the Property Section for further agency utilization. (See GPM 546, "Excess Government Personal Property.")
546 Excess Government Personal Property
a. As a means of expanding the ability of grantees to accomplish NSF objectives while conserving supply and equipment funds, NSF will continue to sponsor the transfer of excess government personal property to NSF grantees.
b. Excess government personal property includes all types of personal equipment and materials (except consumable items such as drugs, paint, etc.), new or used, owned by the Federal Government and no longer needed by the holding agency, but having additional useful life. Under regulations established by the General Services Administration (GSA), the agency charged with operating this program, excess government personal property may be reported to, or requested from, GSA by other Federal agencies, including NSF.
c. NSF will sponsor the transfer of excess government personal property to eligible organizations under one of the following conditions:
1. the use of the property significantly furthers a NSF grant-supported activity;
2. the property is such that it would have been procured under the grant for which property is being requested if additional grant funds had been available;
3. the property is used as part of the grant activity and subsequently for research or science education purposes; or
4. the property is classified by GSA as scientific equipment and has a unit acquisition cost of $1,000 or more. (See GPM 546.6, "Restrictions".)
Eligible organizations are NSF project grantees which are public or private institutions of higher education or non-profit organizations whose primary purpose is the conduct of research or science education activities. State and municipal governments, public health units, hospitals, profit-making firms and individual PI/PDs are not eligible for excess government personal property under NSF sponsorship.
a. To receive information concerning the availability of property, an eligible grantee should contact the Property Administrator, DAS. The Foundation will place the grantee on the list of eligible NSF grantees with the GSA and will provide the grantee with the names, addresses and telephone numbers of GSA Area Utilization Officers (AUO) located near the organization. The grantee should contact an AUO to set up a "needs" list of the scientific equipment required for the NSF project grant. It is important that the NSF grant number and the name of the PI/PD be communicated in all conversations and correspondence regarding excess property acquisitions, transfers and disposals.
b. When GSA information on available excess government personal property is received, the grantee should ascertain whether any items which are necessary to accomplish the supported project are included.
c. Materials and equipment so selected should be inspected whenever possible (see GPM 546.4, "Visiting Holding Agency Facilities"), or the holding Federal agency should be contacted by the grantee to verify the condition of the items, because interpretation of condition codes varies among agencies.
d. If the condition of the item is acceptable, the grantee should freeze (reserve) items by calling the GSA office identified in the catalog. The verbal reservation should then be followed up by a letter. Items are usually allocated on a first come, first served basis. Since GSA may have several freezes on a piece of equipment, first come, first served is interpreted as the first approved written request received by the GSA office. However, preference will be given by GSA to agencies which do not grant title to equipment.
e. The grantee should next prepare and submit to the Property Administrator, DAS, a property request in six copies. A property request consists of SF 122, Transfer Order Excess Personal Property, (Exhibit V-2), and a separate written justification statement. The justification will explain why the property is needed to reduce the cost or enhance the performance under the specific grant for which the property is requested.
f. The SF 122 should be signed by both the PI/PD and the Authorized Organizational Representative. The following information should also be provided on each SF 122:
1. name of grantee organization;
2. grant number;
3. expiration date;
4. the statement "The above equipment is requested for use by the project grantee in support of research or education as outlined in the grant"; and
5. the statement "Transfer is in accordance with the provisions of 41 CFR §101.43."
The transfer order should also identify the automatic release date (from the GSA catalog) to preclude loss of property before the transaction is processed.
g. The written justification should detail the scientific need for the equipment as it relates to the particular grant project under which the equipment is to be used, and should cite the conditions of this section as being binding upon the grantee, should the property be acquired.
h. Upon receipt by NSF, the property request will be reviewed. As confirmation of approval, the grantee will receive copies of the SF 122 from NSF and, subsequently, from the GSA. If the request is disapproved, it will be returned to the grantee with an appropriate explanation.
i. Upon receipt of the requested property, the grantee should immediately return a copy of the SF 122 to NSF as evidence of delivery. Cancellations by GSA, or nonreceipt within a reasonable period of time, should also be reported to NSF after follow-up inquiries have been made to GSA.
546.4 Visiting Holding Agency Facilities
a. Under current GSA regulations all non-Federal grantee representatives wishing to visit holding agency facilities to screen or freeze government excess personal property must receive prior certification from GSA. This certification is not required for those grantees who do their selecting from GSA catalogs and who freeze property only via telephone requests.
b. The number of screeners on a grant should be limited to no more than two persons. The primary screener should be the PI/PD. However, if the PI/PD finds it impossible to screen, he/she may designate, in writing, a substitute.
c. Normally, certification will be on a regional basis; however, NSF will, under certain circumstances, sponsor grantee representatives who need to make interregional visits in order to secure equipment not readily available within their region. Each person who plans to visit holding agency facilities must submit to NSF a completed GSA Form 2946, Authorization Certificate to Select/Freeze Excess Personal Property. This form may be obtained from the Property Administrator, DAS. The GSA Regional Office in which the grantee or organization is located will authorize all regional certifications and serve as principal coordinator on interregional requests. The authorization will be forwarded to the grantee via NSF.
546.5 Dollar Limitation
To ensure equitable distribution of excess government personal property, grantees may be authorized to acquire property under each NSF project grant up to a total acquisition cost equal to the dollar value of that particular grant. Any request for excess property which causes the total to exceed the value of the grant will require additional justification beyond that requested in GPM 546.3. A higher percentage of excess property requested under a particular grant by a grantee must be approved by an administrative level in NSF which is higher than the Program Officer who normally administers the grant. NSF will give full consideration to all factors in determining whether to approve transfers of excess property above the dollar value of a given grant. Grantees are therefore urged to be selective in their requests for excess government personal property to limit quantities of each item where possible and to avoid stockpiling items for future use.
a. NSF will sponsor the transfer of excess government personal equipment to eligible organizations only under "project grants." As defined in the GSA regulations, "project grants" refers to grants made for specific purposes with established termination dates, e.g., grants made to specific organizations to perform specific tasks within set time frames and costs. No excess property may be acquired on behalf of conference grants, publication-support grants or travel grants. In addition, on "summer-type training grants," no property may be acquired after the training period has terminated. Further, grantees should exercise careful judgment on the appropriateness of requesting excess personal property when only a short period of time exists between the date of the property request and the completion or successful accomplishment of the NSF-supported project activity. GSA will consider items of personal property as scientific equipment for transfer without reimbursement to NSF for use by a project grantee when the property requested has a unit acquisition cost of $1,000 or more and is within Federal Supply Classification Groups:
1. 14 (Guided Missiles);
2. 43 (Pumps and Compressors);
3. 48 (Valves);
4. 58 (Communication, Detection and Coherent Radiation Equipment);
5. 59 (Electrical and Electronic Equipment Components);
6. 66 (Instruments and Laboratory Equipment);
7. 67 (Photographic Equipment);
8. 70 (General Purpose Automatic Data Processing Equipment, Software, Supplies and Support Equipment); or
9. 74 (Office Machines and Visible Record Equipment).
Automatic data processing equipment must be acquired under the provisions in 41 CFR §201.23.
b. GSA will give consideration to the transfer without reimbursement of items of excess property in other Federal supply classification groups and items with a unit acquisition cost of less than $1,000, when NSF certifies that the item requested is a component part of or related to a piece of scientific equipment or is an otherwise difficult to acquire item needed for scientific or engineering research. Items of property determined by GSA to be common-use or general purpose property, regardless of classification or unit acquisition cost, shall not be transferred to a project grantee for the purpose of cannibalization, unless the granting agency sends with the transfer request a supporting statement which clearly indicates that disassembly of the requested item for secondary use of its component parts, or for repair and maintenance of a similar item, has greater potential benefit than utilization of the item in its existing form and that a clear cost savings to the government will result, subject to final determination by GSA.
Excess government personal property is usually secured without cost. However, the recipient grantee should specify the method of shipment (see Exhibit V-2) and must pay all costs of packing, transportation and subsequent installation, rehabilitation and maintenance if required. Grant funds may be used to pay such costs.
Title to excess government personal property obtained by academic and other non-profit grantees through NSF sponsorship remains with the government until the property is delivered to the grantee organization. Upon delivery, the grantee should forward to NSF a receipted SF 122 which clearly lists the items of property actually obtained by the grantee. Unless NSF informs the grantee to the contrary, when this SF 122 is received at NSF, title to all property acquired will automatically pass to and be vested in the grantee organization, subject to the understanding that the property will be used for research or for science education purposes as long as it has a useful life. At such time as the property is no longer useful for such purposes, it may be disposed of in accordance with organizational practices, but any proceeds therefrom shall be used by the grantee solely for research or science education purposes. Under certain conditions, such as when highly specialized equipment is involved, NSF may retain title to excess property. When such a condition exists, NSF will inform the grantee. Excess government personal property may not be transferred to a foreign country without the express written approval of DGA.
546.9 Accountability and Recordkeeping
a. While no particular type of classification of accounts or inventory system is required, NSF expects that the responsible officials of the grantee organization will exercise careful stewardship of excess government personal property acquired in support of projects undertaken with NSF's financial assistance. In accordance with GPM 546.5, "Dollar Limitation," relating to the dollar limitation on the amount of excess government personal property provided by NSF, grantees should maintain appropriate inventory procedures which will enable them to identify those requests which require more extensive administrative and scientific justification. In those cases where title to excess government personal property remains with the government, the grantee must maintain suitable records to identify its location, description, utilization and value. The use of excess government personal property under an NSF grant is subject to inspection and audit by representatives of NSF at all reasonable times during the life of the grant under which the property was acquired.
b. Further details may be obtained from the Property Administrator, Division of Administrative Services, National Science Foundation, 4201 Wilson Boulevard, Arlington, VA 22230.
3 For consistency with the DHHS conflict of interest policy, in lieu of "organization", NSF is using the term "institution" which includes all categories of proposers.
4 See On Preventing Conflicts of Interest in Government-Sponsored Research at Universities, a Joint Statement of the Council of the American Association of University Professors and the American Council on Education (1964); Managing Externally Funded Programs at Colleges and Universities, especially "Principle X. Research Ethics and Conflicts", issued by the Council on Government Relations (1989); Guidelines for Dealing with Faculty Conflicts of Commitment and Conflicts of Interest in Research, issued by the Association of American Medical Colleges (1990); and Framework Document for Managing Financial Conflicts of Interest, issued by the Association of American Universities (1993).