Managing Conflicts of Interest and Commitment 

The Federal and State of Florida Concern:

U.S. researchers may be inappropriately influenced by foreign entities when their outside activities with those entities confer personal benefit and/or conflict with their institutional duties.  Personnel or organizations that maintain financial interest in a foreign entity may be inappropriately influenced by that entity to share intellectual property (IP) and/or affect the course of research.  Such financial conflicts are strictly regulated, and most federal, state, corporate, and private sponsors require notification and remediation of such conflict.

Many research sponsors, federal agencies, and the State of Florida now also mandate reporting on a variety of international extra-professional activities and international affiliations; however, required reporting varies widely by sponsor/entity and project type. Most international activities and affiliations do not trigger foreign influence concerns. However, in order to support streamlined and expedient reporting to federal, state, and sponsoring entities, FIU must collect information on institutional and extra-professional activities that occur with international entities.

FIU’s Response:

FIU has updated its Conflict of Interest (COI) and Conflict of Commitment (COC) disclosure processes to capture information which might reflect a potential foreign influence concern. Please refer to FIU HR Outside Activity/Conflict of Interest information and/or HR COI FAQs and Conflict of Interest Research Committee.

Example from the Conflicts of Interest/ Commitment Disclosure form:

• Do you have any appointments, affiliations, activities, interests or collaborative projects (whether paid or unpaid and even if described as honorary, courtesy, adjunct or other similar description) with any foreign university or other foreign entity or foreign government, including any involvement in any talent programs (e.g., programs in which you have been recruited by a foreign university, entity or government)?

ORED’s pre-award coordinators work closely with PIs with respect to required COI disclosures on federal proposal submissions. In addition, the University has updated its procurement screening processes to identify potential COI concerns and developed a COI policy pertaining to institutional officials.  Both of these new processes include filters to identify potential foreign influence concerns.