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An individual outside GSU is required to comply with the GSU Policy on Financial Disclosures in Sponsored Projects when all of the following exist:

1. The individual is considered an Investigator on a sponsored project; and
2. The sponsored project is funded by a PHS Agency; and
3. The outside Investigator is NOT affiliated with another institution that complies with the new Federal Regulation on Promoting Objectivity in Research.

When all three conditions exist, the investigator will provide Disclosure to GSU at proposal submission and complete the GSU CITI training on Conflicts of Interest prior to the project beginning.

An individual outside GSU is not required to comply with GSU’s Policy on Financial Disclosures in Sponsored Projects if any one of the following exists:

1. The individual is NOT considered an Investigator on a sponsored project; or
2. The sponsored project is Not funded by a PHS agency; or
3. The outside Investigator is affiliated with another institution that complies with the new Federal Regulation on Promoting Objectivity in Research.

If the outside Investigator is affiliated with another institution that complies with the new Federal Regulation, the Investigator’s institution will certify to GSU it complies with the Federal Regulation. Nothing additional is required of the outside Investigator by GSU related to Conflicts of Interest.

September 2012

To whom does the Policy on Financial Disclosures in Sponsored Research apply?

The policy applies to GSU employees who submit grants or contracts, or conduct research under certain funding agencies grants or contracts.

Does the policy apply to investigators or others outside GSU who are working on the project?

For projects funded by PHS agencies only, investigators outside GSU must complete training or certify that the investigator has completed similar training at his or her own institution prior to engaging in activities pursuant to the sponsored project. Investigators outside GSU working on projects funded by sources other than PHS agencies are not required to provide the GSU Disclosure of Significant Financial Interest or training.