Research & Sponsored Programs

Conflict of Interest

This page summarizes the responsibilities of all USD Investigators.  It is not intended to either adopt or be more stringent than the relevant National Institutes of Health (NIH) regulations.

The university's Conflict of Interest Review Board meets as needed during the academic year to identify real or potential financial conflict of interest (FCOI), recommend management plans to the Vice President for Research, and monitor the implementation of those plans.  The board comprises faculty from a broad range of departments and the Office of Research and Sponsored Programs staff.

What are my responsibilities?


All USD Investigators must:

  • Submit disclosures yearly and updates as needed

Public Health Services (PHS)-funded Investigators (Organizational Chart) must

  • Complete required online training every 4 years at www.citiprogram.org (Conflict of Interest, Stage 1)
  • Submit disclosures yearly and updates as needed
  • Understand that some details of investigators' FCOI management plans must be made available upon request

Conflicts of interest in research may occur when outside financial interests compromise, or have the appearance of compromising, the professional judgement of a researcher when designing, conducting, or reporting research.  In the event of an FCOI, a management plan will be put in place by the Conflict of Interest Committee.  Examples of conditions or restrictions that might be imposed to manage FCOI include but are not limited to:

  • Public disclosure of the FCOI (e.g. when presenting or publishing research)
  • Disclosure of FCOI directly to participants in human subjects research
  • Appointment of an independent monitor capable of taking measures to protect the design, conduct, and reporting of the research against bias resulting from FCOI
  • Modification of the research plan
  • Change of personnel or personnel responsibilities, or disqualification of personnel from participation in all or in portions of the research
  • Reduction or elimination of FCOI (e.g. sale of an equity interest)
  • Severance of relationships that create financial conflicts

Each person conducting research under a management plan must comply fully and promptly with the plan.

NIH Financial Conflict of Interest Frequently Asked Questions

For more information, please contact the Office of Research and Sponsored Programs at (605) 677-5370.