UMass Policy for Compliance with NSF and Other Federal Agency's Financial Disclosure Regulations

Revised 4/6/2012

Under the Federal financial disclosure regulations, a conflict of interest exists when it can be reasonably determined that an investigator's personal financial concerns could directly and significantly influence the design, conduct, or reporting of government funded research activities. Faculty and staff of the University of Massachusetts Amherst (the University) have an obligation to maintain the objectivity of their research, avoiding any conflict of interest. This Conflict of Interest in Research and Scholarly Activity Policy has been developed by the University of Massachusetts Amherst and complies with specific NSF requirements laid out in NSF’s Grant Policy Manual.  Every investigator participating in NSF funded research must comply with this requirement. University employees are reminded that, in addition to the provisions of this policy, activities of University employees are subject to the requirements of the University of Massachusetts Policy on Conflicts of Interest Relating to Intellectual Property and Commercial Ventures.


As used in this Policy:

Investigator means the principal investigator and any other person who is responsible for the design, conduct, or reporting of research funded by NSF , or proposed for such funding. For purposes of the requirements of this subpart relating to financial interests, “Investigator” includes the Investigator's spouse and dependent children.

Research means a systematic investigation designed to develop or contribute to generalizable knowledge relating broadly to science and engineering , including behavioral and social-sciences research. The term encompasses basic and applied research and product development. As used in this Policy, the term includes any such activity for which research funding is available from an NSF Awarding Component through a grant or cooperative research agreement.

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 interests (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 SBIR Program;

(3) Income from seminars, lectures, or teaching engagements sponsored by public or nonprofit 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 represent more than a five percent 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 over the next twelve months, are not expected to exceed $10,000.

Small Business Innovation Research (SBIR) Program is the extramural research program for small business that is established by the Awarding Components of the NSF  and certain other Federal agencies under Pub. L. 97-219, the Small Business Innovation

Development Act, as amended. For the purposes of 42 CFR Part 50 Subpart F the term SBIR

Program includes the Small Business Technology Transfer (STTR) Program, which was established by Pub. L. 102-564.


Each investigator covered by this policy will annually report all "significant financial interests" held by themselves, their spouse and dependent children. Disclosures will be made by completing the DISCLOSURE OF SIGNIFICANT FINANCIAL INTEREST FORM at the end of this document, and sent to the Department Head/Chair, the Dean and the Vice Chancellor for Research and Engagement on an annual basis and when new significant financial interests are acquired. A disclosure form must be completed prior to the submission of an application for NSF grant or cooperative research agreement.  Care should be given in every proposal to disclose any relationship where the Investigator(s) have a financial interest that would be of interest to the sponsor, since every Federal agency requires honesty and transparency in the proposal process.

Positive disclosures will be reviewed by the Department Head/Chair and Vice Chancellor for Research and Engagement (or designee). Ad hoc reviewers may be consulted on a case-by-case basis. In those cases where, in consultation with a faculty member involved, the Vice Chancellor for Research and Engagement (or designee) determines that a real or apparent conflict exists, one of the following actions will be taken: l) Accept the sponsored project; 2) Not accept the sponsored project; 3) Accept the sponsored project subject to certain conditions, e.g.,

(i) public disclosure of significant financial interests;

(ii) monitoring of research by independent reviewers;

(iii) modification of the research plan;

(iv) disqualification from participation in all or a portion of the research funded by the PHS;

(v) divestiture of significant financial interests; or

(vi) severance of relationships that create actual or potential conflicts.

Appeal of the decision may be made to the Provost, who will consult with the Investigator and the review committee before making a final determination, within thirty days of the appeal, as to the action to be taken. In all cases, resolution of the actual or apparent conflict of interest will be achieved before the University implements a sponsored project.

Prior to the University's expenditure of any funds under the award, the University will report to the Awarding Component the existence of a conflicting interest (but not the nature of the interest or other details) found by the institution and assure that the interest has been managed, reduced or eliminated in accordance with the NSF requirements. For any interest that the University identifies as conflicting subsequent to the Institution's initial report under the award, the report will be made and the conflicting interest managed, reduced, or eliminated, at least on an interim basis, within sixty days of that identification.

The Institution agrees to make information available, upon request, to the NSF regarding all conflicting interests identified by the Institution and how those interests have been managed, reduced, or eliminated to protect the research from bias.


Failure to comply with the above Policy will subject the Investigator to the University's Scholarly Misconduct Policy . University employees are reminded that if the failure of an Investigator to comply with the conflict of interest policy of the University has biased the design, conduct, or reporting of the NSF-funded research, the University will promptly notify the NSF Awarding Component of the corrective action taken or to be taken. The NSF awarding Component will consider the situation and, as necessary, take appropriate action, or refer the matter to the University for further action, which may include directions to the Institution on how to maintain appropriate objectivity in the funded project.


The University will maintain the Disclosure Form and other records of all financial disclosures and all actions taken by the Institution with respect to each conflicting interest for at least three years from the date of submission of the final expenditures report or, where applicable, from other dates specified in 45 CFR 74.53(b) for different situations. Records will be maintained in the Office of the Vice Chancellor for Research and Engagement. All disclosures and related documentation are considered confidential, and only those persons involved in the implementation of this policy will have access to such records.


As required by NSF, the University will report the existence of a conflict of interest which is unable to be resolved within the University to the NSF Office of the General Counsel.