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NSF Financial Conflict of Interest Requirements

The NSF Proposal & Award Policies & Procedures Guide, effective for proposals submitted, or due, on or after February 24, 2014, includes an addition to the Certification Regarding Conflict of Interest (Chapter II.C.1.e, Proposal Certifications).  Currently, NSF requires institutions to report to the agency project related conflicts of interest that cannot be managed or eliminated.  The new regulations require institutions to also report conflicts that are identified a posteriori, when NSF sponsored research has been conducted for which an existing conflict was not properly disclosed, identified, and managed (i.e., “research that proceeds without the imposition of conditions or restrictions when a conflict of interest exists, must be disclosed to NSF via use of the Notifications and Requests Module in FastLane”).

Investigators on current and pending NSF research awards are required to review and update their research related Significant Financial Interest disclosures, as needed. Financial interests acquired since the beginning of an ongoing NSF sponsored project, or proposal submission to NSF, should be disclosed or updated using the Proposal Driven Disclosure online application (please use the My Disclosures tab).

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