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CUNY’s policy and procedures addressing conflict of interest (COI) are designed to ensure that all activities are conducted according to the highest standards of integrity and ethics. They apply to the University’s officers, full- or part-time employees of the University, and all students and post-doctoral fellows.
CUNY Significant Financial Interest (SFI) Disclosure Forms
The City University of New York is an institution of public trust; investigators must respect that status and conduct research in ways that will not compromise the integrity of the University or that trust.
Who is an investigator?
According to the CUNY policy on Conflict of Interest, an investigator is the project director, principal investigator, co-principal investigators, and any other person, regardless of title or position, responsible for the design, conduct, or reporting of a University Sponsored Project. Examples include collaborators or consultants, whether or not the University or the Research Foundation employs such individuals.
Here are some examples:
| Title/Role in Research | Investigator? | Guidance |
| Principal Investigator | Yes | |
| Co-Investigator | Yes | |
| Graduate or Postdoctoral Fellows on paid fellowships | Yes | |
| Collaborators at sub-recipient institution | Yes, if involved in design, conduct or reporting of research |
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| Collaborators at CUNY campuses other than that of the PI | Yes, if involved in design, conduct or reporting of research | Submit disclosure forms to the CCO at the campus where the investigator has the primary CUNY appointment. |
| Collaborators not affiliated with CUNY, and who are not sub-recipients | Yes, if involved in design, conduct or reporting of research | Submit disclosure forms to the CCO at the campus where the PI has the primary CUNY affiliation |
| Consultants | Maybe | Consultants are typically paid a fee in exchange for expert opinion and advice to researchers. They are not usually responsible for the design, conduct or reporting of research, but an analysis must be done to make this determination. |
At the time that the Principal Investigator submits a grant proposal or application, each investigator must complete the relevant CUNY Significant Financial Interest (SFI) Disclosure Form and submit it to the college Grants Officer and the College Conflicts Officer (CCO).
When submitting a grant proposal to the U.S. Public Health Service1, investigators must complete the two forms found here, and for proposals to a non-PHS entity, investigators must complete the two forms found here.
The CCO receives and reviews the financial conflict of interest disclosure forms and ensures compliance with any applicable conflict management plans issued by the CUNY Conflicts Committee.
An updated CUNY Significant Financial Interest Disclosure Form will be needed as follows:
- Each investigator must submit an updated form to the college Grants Officer and CCO when the Principal Investigator submits an annual progress report.
- Each investigator is required to submit an updated form to the college Grants Officer and the CCO within 30 days of any material change in the previously disclosed SFI, discovery or acquisition of a new SFI, or when the investigator joins an ongoing research project at CUNY.
At the CUNY Graduate School of Public Health and Health Policy (CUNY SPH), the CCO is Michele Kiely, and Michele can be reached via email at Michele.kiely@sph.cuny.edu.
At CUNY SPH, Grants Officers can be reached via email at SPaR@sph.cuny.edu.
Training in Conflict of Interest
All investigators engaging in research related to any Public Health Service (PHS) funded grant or contract, Conflicts Committee members, and all CUNY College Conflicts Officers are required to complete the CITI training in Conflict of Interest (COI). In addition, a CCO or the CUNY Conflicts Committee may require individuals to complete this course on a case-by-case basis. Individual training requirements may be based on the nature of an existing conflict, non-compliance with CUNY’s Conflict of Interest Policy, or non-compliance with a Conflict of Interest management plan. The COI training certificate will be valid for four years. CUNY researchers are required to re-take the CITI COI training course every four years.