Title : iin118 - IMPORTANT NOTICE Investigator Financial Disclosure Policy Date : October 7, 1996 ************************************************************************* NOTE: Posting of previously unavailable files 10/7/96 wcg ************************************************************************* NATIONAL SCIENCE FOUNDATION Office of the Director ARLINGTON, VIRGINIA 22230 Notice No. 118 July 13, 1995 IMPORTANT NOTICE TO PRESIDENTS OF UNIVERSITIES AND COLLEGES AND HEADS OF OTHER NATIONAL SCIENCE FOUNDATION GRANTEE ORGANIZATIONS Subject: Investigator Financial Disclosure Policy The National Science Foundation issued its Investigator Financial Disclosure Policy on June 28, 1994. NSF has been coordinating its Policy with the Department of Health and Human Services (HHS) which is also issuing a rule on this subject. NSF recently changed the Policy's effective date from June 28, 1995 to October 1, 1995, so that it coincides with the effective date of the final HHS rule. NSF is now making certain other technical changes and clarifications to further conform its Policy to the HHS rule. See 60 Fed. Reg. 35820 (July 11, 1995). The technical changes and clarifications are as follows (the revised Policy is included as an attachment to this Important Notice): . Subparagraph b of GPM 510 will be revised to require disclosure to the institution's representative of significant financial interests that "would reasonably appear to be affected" by the activities funded or proposed for funding by NSF. Previously, the provision had required disclosure of financial interests that "reasonably appear to be directly significantly affected" by such activities. . For greater clarity, the exclusion set out in subparagraph b.5 of GPM 510 will be split into two separate exclusions -- one for equity interests and one for other types of payments. Also, the dollar threshold has increased from $5,000 to $10,000. . In subparagraph d of GPM 510, the definition of a conflict of interest will be revised to include instances in which the reviewer(s) of disclosures determines that a significant financial interest "could directly and significantly affect the design, conduct or reporting of" NSF-funded activities. This revision, in conjunction with the above revision to subparagraph b of GPM 510, now makes the institutional reviewer -- instead of the investigator at the time of disclosure -- responsible for determining whether a significant financial interest could directly and significantly affect such NSF-funded activities. The previous definition and disclosure requirement had the opposite effect. . The Certification for Authorized Institutional Representative or Individual Applicant has been change to require the institutional representative to certify that any identified conflicts of interest will be managed, reduced or eliminated "prior to the institution's expenditure of any funds under the award." The certification previously required resolution of conflict "prior to funding the award." This technical change therefore eliminates the need for institutions to review and resolve conflicts in proposals that do not get funded. . The Policy has been revised to delete the additional Certification for Principal Investigators and Co-Principal Investigators that was previously to be included in the Grant Proposal Guide. Section II.C1 of Part II of the Grant Proposal Guide and Page 2 of the NSF Form 1207 will now contain a single certification to be completed by the institutional representative. . The Policy has been clarified to apply not only to proposals submitted on or after October 1, 1995, but also to certain large ongoing projects such as centers and other activities that are currently being funded by NSF on an incremental basis through cooperative agreements or other agreements for which new proposals may not be submitted for several years. NSF will require that institutions and investigators involved in such projects, at the time of their first funding increment which occurs after October 1, 1995, provide the certifications required by the Policy for all cooperative agreements and for all continuing grant increments exceeding $1,000,000. Such awardees will be advised in advance in writing by the Grants Officer that they will be required to have a policy in place and submit the required certifications as a condition of future funding increments. . In addition to the technical changes and clarifications described above, NSF has made a small number of minor word changes to resolve minor inconsistencies between its policy and the HHS rule. None of these changes is intended to alter the meaning of any provision in the Policy. NSF will continue to collaborate with HHS to help institutions implement and enforce consistent conflict of interest policies that protect the integrity of both NSF- and HHS-funded activities. To that end, the agencies will be working together to develop common implementation guidance, including a set of questions and answers. As we all gain experience with this Policy over the next several years, I encourage you to provide us with your comments so we can make appropriate changes or revisions that take your views into account. Neal Lane Director Attachment (Federal Register, Vol. 60, No. 132, Tuesday, July 11, 1995, pages 35821-35823 available in paper edition only.) .