Conflict of Interest FAQs

A “conflict of interest” occurs when professional actions or decisions are influenced by personal considerations, financial or otherwise; the term also includes unauthorized use or misuse of UNH resources in the course of an external activity.

A related concept is “conflict of commitment,” which occurs when time or effort devoted to external activities by faculty, extension educators, or staff interferes with fulfillment of their assigned UNH responsibilities.

The Conflict of Interest and Commitment policy (see the link above) applies to all UNH faculty, extension educators, and staff.

Anyone who is an “investigator” on an externally funded research project, whether funded by a grant, a contract, or other arrangement, must also comply with the Financial Conflict of Interest in Research (“FCOIR”) policies (see the links above).  An “investigator” is defined as the project director or principal investigator and any other person, regardless of title or position (e.g., consultants, unpaid collaborators), who is responsible for the design, conduct, or reporting of research funded by external sources, or proposed for such funding.

What is a “financial conflict of interest in research” (FCOIR)?

A “financial conflict of interest in research” exists when it can be reasonably determined that an investigator’s personal financial concerns could directly and significantly influence (or be influenced by) the design, conduct, or reporting of sponsored research activities.  UNH faculty and staff have an obligation to scrupulously maintain the objectivity of their research and avoiding any conflict of interest – financial or otherwise.

A financial interest can be comprised of anything of monetary value, whether or not the value is readily ascertainable.  Under the UNH FCOIR policies, an investigator must file a form with the Office of the Senior Vice Provost of Research, if the investigator (or his/her spouse, domestic partner, or dependent child) has a “significant financial interest” that requires disclosure.  The basic thresholds for disclosure depend on the funding agency (see the policies for more specific details):

Yes.  UNH must flow-down FCOIR terms, along with other award terms, to any of our subawardees or subcontractors.  A subrecipient may elect to follow UNH’s PHS FCOIR policy if the sub has not enacted its own policy.  Subawards or subcontracts will not be issued until all FCOIR issues have been resolved.  Contact your Grant/Contract Administrator to discuss when and how this must be accomplished.

Find your Grant/Contract Administrator

Training and education are important components of UNH’s Conflicts of Interest compliance.  Both in-person training and online training are available.

For online training, USNH uses the CITI Program online Conflicts of Interest courses. (The UNH Conflicts of Interest and Commitment training module was retired on August 30, 2024.)  To access a USNH CITI Program course, individuals need to use University System of New Hampshire as their organization when logging into the CITI Program, not University of New Hampshire as the latter is not listed. See this guidance for accessing the CITI Program courses via USNH Single Sign On.

In-person training is also available for any individual or group of faculty, staff or students who would like more specific guidance regarding the application of FCOIR policy at USNH.  To schedule a training session, please contact Research Integrity Services.

CITI training