COI Frequently Asked Questions
The following FAQs are provided to address commonly answered questions from researchers.
General Issues
1. What if I am the Project PI and I have a COI?
If the Investigator is the project PI, ORED will not issue the Project ID until the COI in research process has been completed and it concluded that a monitoring plan is not needed or if it is needed, that monitoring plan is in place. If the Investigator at issue is not the project PI, then ORED may release the Project ID to the PI once all ORED Pre-Award processes are concluded, and if the Project ID is released, it shall be the responsibility of the PI to ensure that the subject Investigator does not begin work on the project until ORED notifies the project PI that all conflict of interest matters have been resolved, which includes the Investigator agreeing in writing to comply with the monitoring plan.
2. What are some examples, and are not limited to, when a monitoring plan is needed?
• Interests that are similar to or take advantage of your position, activities or expertise at the University.
• You maintain a consulting practice in an area for which you are similarly responsible for developing and/or managing on behalf of the University.
• Outside interests that take advantage of your access to University-owned information or intellectual property, resources or personnel.
• If your outside activities license (or should license) or otherwise uses the University’s information or intellectual property, that will be deemed to be a related or overlap with a University activity.
• Outside interests that use the information or intellectual property that you acquired or use in connection with your institutional activities.
• Relationships and activities that are related to your FIU responsibilities (teaching, research, service on committees).
• Financial interests in an organization that is related to your work at FIU- consulting, advising, speaking, etc. if the organization is related to your field and/or could benefit from your professional expertise.
• Ownership of, or investment in, a start-up company related to your field even if it is just “on paper” or worth nothing.
3. What is a considered a conflict of interest in research?
A conflict of interest arises when an individual’s financial, personal or outside interests may compromise or bias or be perceived to compromise or bias their professional judgement and objectivity in conducting or reporting research.
Conflicts of interest are the result of situations which might create the perception of bias, rather than any specific actions by an individual. For this reason, perceived conflicts are considered conflicts of interest whether or not they have materially impacted an investigator’s actions. It is important to understand that the determination of a conflict of interest is an acknowledgement of such a situation, not an implication of any wrongdoing or impropriety.
4. How can the Conflict of Interest arising from an SBIR/STTR be managed?
Management plans will be conceived and drafted individually based on the facts of a conflict, but all management plans pertaining to an SBIR/STTR will disallow the following:
Self-Reporting: The same person cannot be named Principal Investigator on both FIU’s and the outside company’s proposal. If you intend to be Principal Investigator with respect to the work occurring at FIU under the SBIR/STTR, the Principal Investigator named at the company should be a full-time employee of the Company, preferably one who does not report directly to you in the company hierarchy. If you prefer to be named Principal Investigator for the company, the FIU PI should be a faculty member who does not report to you.
Hiring of personnel: Employees of the company should not be given roles at FIU or access to FIU’s resources and facilities as a result of the collaboration, or otherwise be paid by FIU for services rendered without prior FIU approval.
Use of FIU Resources: The company should not use FIU address, facilities, or resources, including personnel, without prior notice and written approval from the Office of Research and Economic Development (ORED).
