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Financial conflict of interest (FCOI) in research and other sponsored activity may occur when outside financial interests compromise, or have the appearance or potential of compromising, the professional judgment of key personnel designing, conducting or reporting research. The objectivity of research is of vital importance and is the basis of obtaining and maintaining public trust. 

If you are submitting a proposal to a PHS agency, it is a federal requirement that you must submit a Financial Conflict of Interest Disclosure even if there is no FCOI present. �鶹��ýӳ�� also requests FCOI disclosures of all externally sponsored research through any federal agency or private foundation. You must also complete required FCOI/RCR training once every four years. 

We recommend you review the following policies and links to understand �鶹��ýӳ�� policy and federal requirements: 

• �鶹��ýӳ��’s Financial Conflict of Interest Policy and Procedures for Sponsored Programs
• Required Trainings (see below) 
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• Financial Interest Disclosure Form 1
• Financial Interest Disclosure Form 2

• At Time of Proposal: It is a requirement of PHS and other federal agencies that you submit an FCOI at the time of the proposal. OSP must review and certify your disclosure form(s) before your proposal can be submitted to the agency 
• At Award Set Up: For a new award, or a new amendment to an existing award, an FCOI disclosure form must be updated/resubmitted once the award is received. The award will not be executed until the FCOI form has been submitted, reviewed and certified. 
• Annually: Disclosures must be updated at least annually. Investigators will only be notified to update their disclosure annually if no action has been taken in the last 12 months. 
• Within 30 days of a new Significant Financial Conflict of Interest (SFI): A revised COI disclosure must be made within 30 days of discovering or acquiring a new significant financial interest (e.g.: through purchase, marriage or inheritance). 

• �鶹��ýӳ�� is dedicated to the highest standards of research integrity and is committed to responsible and ethical conduct for all those involved in research, including research funded through training awards, career development awards, research education awards, and dissertation research awards.
• All University faculty, staff, postdoctoral researchers, and students are required to be trained in Responsible Conduct of Research (RCR) and provide training completion certificates to the University PRIOR to their involvement in any research.  It is strongly encouraged that all RCR training be completed, and completion certificates provided to the University, at the time of submission of a proposal to an external funder.  No research funding can be accessed prior to fulfilling the University’s RCR training requirements.
• Standard topics covered by the RCR training include: (i) Research misconduct, (ii) Mentoring/trainee responsibilities, (iii) Peer review, (iv) Publication practices & responsible authorship, (v) Data acquisition, management, sharing & ownership, (vi) Conflict of interest & commitment, (vii) Collaborative research, (viii) Research involving human subjects, (ix) Animal welfare, (x) Safe Laboratory Practices, (xi) Social Responsibility, and such other matters as the University may determine from time to time.
• RCR training can be found in the University's Collaborative Institutional Training Initiative (CITI) online training modules.  Additional training resources are also provided by the National Academy of Sciences and The Office of Research Integrity (ORI) – U.S. Department of Health and Human Services. Contact grants@yu.edu for more information about the required training.
• Training completion certificates must be provided to the University’s Office of the Sponsored Programs at the time of proposal, or no later than the time period before an award is released.
• It is the responsibility of the Principal Investigator/Project Director (PI) to ensure that all research team members are informed of, and comply with, this training requirement. Moreover, it is the PI’s responsibility to provide appropriate mentoring through discussions of RCR topics and through oversight of the research project and to collect and submit all required training completion certificates.
• Training must be completed at least every four (4) years.
• This training requirement is intended to satisfy the training requirements of the National Institutes of Health (NIH), the National Science Foundation (NSF), the U.S. Department of Agriculture and other agencies, and may be modified or amended from time to time to ensure compliance with such requirements or as the University deems appropriate.
• As mentioned previously, all faculty, student and staff members working on a federally funded award must complete RCR training. They must also take a refresher training no less than every four years. If a new employee or student joins the project and was not part of the original proposal, the Principal Investigator must have that new member go through RCR training. If there are any questions regarding this matter, please contact our office and we may assist you.

OSP will work with key research personnel to verify training at the time of proposal and award, as applicable. A copy of the certificate of completion is required from the researcher(s) before the award can be signed and released. The RCR training requirement applies to all key personnel, as well as to all sub-recipients under �鶹��ýӳ�� awards. �鶹��ýӳ�� uses an online training program from CITI to meet RCR training requirements.

CITI Training Program

To access courses:

1. Go to ,
2. Register, selecting �鶹��ýӳ�� as a CITI Program subscriber organization,
3. Agree to the Terms of Service and affirm your affiliation with �鶹��ýӳ��
4. Continue to create your CITI Program account
5. Select the appropriate modules that corresponds to your area of research:
   Biomedical Responsible Conduct of Research
   Responsible Conduct of Research for Engineers
   Humanities Responsible Conduct of Research
   Physical Science Responsible Conduct of Research
   Social and Behavioral Responsible Conduct of Research
   Responsible Conduct of Research for Administrators

�鶹��ýӳ�� is committed to ensuring the integrity of research. We understand the importance of protecting the integrity of research for the greater good of society. All faculty, staff, scholars and students are expected to uphold honesty and ethics in conducting research.

Research misconduct is defined as fabrication, falsification, or plagiarism in proposing, performing, or reviewing research, or reporting research results, where:

• Fabrication is making up data or results and recording or reporting them
• Falsification is manipulating research materials, equipment, or processes, or changing or omitting data or results such that the research is not accurately represented in the research record
• Plagiarism is the appropriation of another person's ideas, processes, results, or words without giving appropriate credit

It is the responsibility of all �鶹��ýӳ�� faculty, staff, scholars and students to report research misconduct, and to assure that such reports are dealt with in a timely, effective, and fair manner.

In compliance with federal requirements, �鶹��ýӳ�� has implemented an official Scientific Misconduct Policy, that outlines procedures and processes for research misconduct claims. The Scientific Misconduct Policy can be found here.

If you would like to discuss anonymously or unofficially an incidence of possible research misconduct or have questions about the process, please contact any of the following:

Selma Botman
Provost and VP of Academic Affairs
selma.botman@yu.edu

Jennifer B. Kinney
Director of Sponsored Programs 
Director of Research Policy & Integrity
jennifer.kinney@yu.edu

Ed Berliner
Dean of Science Management
eberline@yu.edu

A Foreign Talent Recruitment Program (FTRP) is an effort organized, managed, or funded by a foreign government or entity to recruit science and technology professionals or students (regardless of citizenship or national origin, or whether having a full-time or part-time position). FTPRs generally involve two elements: 1) compensation from a foreign country or entity to the researcher in exchange for 2) specific research activities, opportunities, or obligations that may create a risk of conflict of interest, conflict of commitment, loss of IP, or other risks. Compensation need not be cash but could include in-kind contributions, access to resources, research funding, titles, travel, or items of non-de minimis value. FTRPs are not limited to programs with an explicit purpose of recruiting personnel but may have broader goals (e.g.: to recruit the targeted individual to support the foreign country’s research and development initiatives in exchanges for benefits to the individual being recruited).

The prohibits participation in a Malign Foreign Talent Recruitment Programs (MFTRP) by individuals involved with federal research and development awards. MFTRPs most often involve China, Iran, North Korea, or Russia, or entities in those countries, and must meet certain other criteria. Federally funded researchers are required to certify that they are not participating in MFTRPs. NSF requires certification effective March 20, 2024, and the DOD will require certification starting August 2024. Other federal agencies have not published timelines for this certification. The certification has been added to the US Government’s common disclosure forms for Current and Pending (Other) Support and the Biographical Sketch.

Participation in a Malign FTRPs by federally-funded researchers is prohibited under federal law and University policy.

FTRPs raise research security concerns. If you believe you have been contacted by an FTRP, or have any other questions, please reach out to OSP.

• The DOD has published a (page 18)
• White House has for federal agencies regarding FTRPs
• The NSF has revised the with new language and certification requirements for addressing MFTRPs

For reasons of national security and trade protection, the United States has enacted export control laws to govern the transfer of certain information, items, or technologies to foreign countries and foreign persons.  These laws apply to items that have a military application, as well as to commercial items that may have a potential military application or pose a foreign policy or national security concern.  �鶹��ýӳ�� is committed to complying with applicable U.S. laws and regulations pertaining to export of items, services and technology on behalf of the University.

For universities, the most pertinent export control regulation is the Fundamental Research Exclusion (FRE) as identified in the National Security Decision Directive (NSDD) 189.  This directive defines fundamental research and declares that federally sponsored university research should be unimpeded by export controls unless there are legitimate national security concerns at stake.

• The export from the United States to a foreign country of certain items, information, or software;
• Verbal, written, electronic, or visual disclosures or transfer of scientific and technical information related to controlled items to foreign persons (“deemed exports”) or entities inside or outside the United States;
• Transactions with, or travel to, certain sanctioned or embargoed countries for the conduct of activities such as teaching or research, or attending conferences; and
• Financial transactions, exports, re-exports, and deemed exports of items and information to Restricted Parties or End Users, or for Restricted End Uses.

The list of controlled items and information is in the  or .

Three types of activity are generally not subject to export control regulations:

• Fundamental Research: basic and applied research of which the results are published and shared broadly with no access restrictions ()
• Educational Information: general scientific, mathematical, or engineering principles commonly taught in schools, colleges, and universities ()
• Public Domain Information: information which is published and which is generally accessible or available to the public ( and )

Most research at �鶹��ýӳ�� is excluded from the export control laws via the “fundamental research” exclusion, which includes “basic and applied research in science and engineering, the results of which ordinarily are published and shared broadly within the scientific community.” However, research work that is not excluded must assess possible conflicts.  It is the responsibility of each �鶹��ýӳ�� employee to assess their research work to determine how export controls might apply to their activities. 

Violations of export regulations can result in extremely high fines for both the individual and the institution involved. Criminal violations can result in imprisonment. University personnel should familiarize themselves with export regulations minimizing and identify when their activities may trigger export controls. If you think an activity may be subject to export control regulations, please escalate the question to the Director of the Office of Sponsored Programs and Research Policy & Integrity.

The IRB process is utilized to protect the rights and welfare of human research subjects recruited to participate in research activities conducted under the auspices of the institution with which it is affiliated. �鶹��ýӳ�� partners with WCG IRB on all IRB applications.

For multi-site NIH research, please review policy expectations for the use of single IRB (sIRB) on .

The Office of the Dean of Science Management handles IRB oversight for �鶹��ýӳ��. Please contact Ed Berliner, Dean of Science Management, for any information and inquiries at eberline@yu.edu.