Conflict of Interest

APM 505: Interim Policy on Conflict of Interest

Conflict of Interest law seeks to minimize the extent to which public employees pursue their own financial interests at the expense of public interest. 

Investigators are required to disclose Significant Financial Interest (SFI) whenever an investigator applies for funding from National Science Foundation (NSF), Public Health Service (PHS) agencies (e.g., NIH), or other agencies adopting federal requirements. Investigators must disclose SFI annually during the life of a sponsored research project, and within 30 days of discovering or acquiring a new SFI.

PIs requesting funds from state, county, and city government are exempt from filing conflict of interest forms. Exempt sponsors are listed in this document: FPPC List of Exempt Agencies- List begins on Page 3.

Federal Disclosure Form: Download Federal Disclosure Form

PIs applying to federal agencies requiring financial conflict of interest disclosure (e.g., NIH, NSF) must complete the Federal Disclosure Form.

Federal Disclosure Requirement

(1) Principal Investigators and key personnel are required to submit a disclosure statement at the proposal submission stage and every year during the life of the grant or contract, unless disclosure is triggered by another event prior to an annual disclosure.

(2) Principal investigators and key personnel are required to complete financial conflict of interest training prior to engaging in research related to any PHS-funded grant or contract and every four (4) years after award for the life of the grant or contract. Training is offered through Collaborative Institutional Training Initiative (CITI) Program. CITI Program’s conflict of interest courses cover the U.S. Public Health Service (PHS) regulations on financial conflicts of interest and an investigator's responsibilities related to the disclosure of Significant Financial Interests.

CITI Conflict of Interest Training Instructions

List of Agencies that Adopted Public Health Service (PHS) Financial Conflict of Interest (FCOI) Policy: List of Agencies

California Form 700-U: Download 700-U Form 

PIs requesting funding from nonexempt non-governmental sources must file the one-page California Form 700-U. 

California Regulations Require

(1) Filing of form 700-U for an initial submission of a grant or contract (before the final acceptance of a contract, grant, or gift);

(2) Filing of form 700-U within 30 days after the contract, grant, or gift is renewed. California State University, Fresno defines “renewal” as a competitive renewal (i.e., the PI must apply for the grant).

(3) CSU system-wide ethics training must be completed within 30 days of receiving the grant or contract. Subsequent training is required every two years that the grant or contract is active. Training is administered through the Human Resources department via the CSULearn system training portal.