Policies and Procedures
OSP staff, located in Scharbauer Hall, Suite 1016, can assist in proposal development and identification of possible funding sources. Annual registers of grant support, newsletters, funding sources and alert systems, agency directories, contracts and grants policy manuals, as well as an online sponsor search service are available for use by faculty and staff.
National Institutes of Health (NIH) Other Support Training
Policy Statement
Texas Christian University (TCU) requires all Senior/Key Personnel on proposals or awards from the National Institutes of Health (NIH) to disclose all research activities and affiliations (active and pending) in Other Support.
All Senior/Key Personnel on proposals to or awards from all federal funding agencies, including the NIH, must fully understand their responsibility to disclose all resources made available to them in support of and/or related to all of their research endeavors, regardless of whether or not they have monetary value and regardless of whether they are based at TCU.
Requirement
Texas Christian University (TCU) is implementing the National Institute of Health’s NIH’s policy requirement for all Senior/Key Personnel on proposals to or awards from the NIH to review the following information and complete the on-line training identified in the training process below to ensure accurate, complete and timely disclosures in NIH submissions:
- NIH Grants and Funding – Other Support topic page: Other Support | Grants & Funding
- NIH Pre-award and Post-award Disclosures Related to the Biographical Sketch and Other Support: NIH Disclosures Table (PDF)
- NIH Other Support Instructions: NIH Other Support Instructions
Training Process
- All Senior/Key Personnel must complete the Collaborative Institutional Training Institute (CITI) Research Security online training module prior to proposal submissions to NSF, NIH, DOE or USDA.
- All Senior/Key Personnel on existing NIH or USDA awards must complete the CITI Research Security online training module prior to submitting a Research Performance Progress Report (RPPR). PIs are responsible for confirming that all Senior/Key personnel have completed the required training prior to submitting the RPPR.
- Any new Senior/Key Personnel added during the course of an existing NIH or USDA award must complete the CITI Research Security online training module.
- The CITI Research Security online training must be renewed annually for all Senior/Key Personnel in proposals and awards.
Non-Compliance
Institutional consequences for failure to comply with this policy may result in:
- At the proposal stage: Delays or prevention of proposal submission.
- At the award stage: Withholding institutional approval to access or spend external grant funds.
Federal sponsor consequences for failure to comply with this policy may result in:
- Federal agency may withdraw applications
- Federal agency may suspend awards
- Federal agency may impose additional oversight if disclosures are found incomplete or inaccurate
Conflict of Interest (COI) and Foreign Influence
Texas Christian University’s (TCU) position is that research, either proposed or funded, should not be biased by a COI or undue influence. TCU is committed to supporting our investigators in their research endeavors and fostering an entrepreneurial spirit while maintaining objectivity, integrity and compliance with sponsor regulations. TCU supports and encourages international collaborative research and highly regards our partnerships with universities and other organizations worldwide for the strength those partnerships bring to TCU’s investigators, research programs and students. Through transparency and disclosure, it is possible for interaction between industry, international collaborators and TCU investigators to take place in a manner that is consistent with the highest traditions of research.
TCU complies with the Public Health Service (PHS) 2011 revised Federal regulation on Financial Conflict of Interest (FCOI) Promoting Objectivity in Research, 42 CFR Part 50 Subpart F through our Research Financial Conflict of Interest Policy. TCU’s policy prescribes a FCOI program intended to promote objectivity of research through a process of disclosure, review, mitigation, and monitoring that will comply with the conflict of interest requirements of our sponsoring agencies.
In order to support research and continued collaborations, it is important that TCU investigators understand the concerns being raised by our federal sponsors and how we address them through transparency. Federal sponsors, Congress, federal agencies, and the White House have all issued some form of communication, guidance, new regulations or clarified policies related to dealing with the issue of undue foreign influences on research integrity. For TCU investigators, comprehensive disclosure ensures transparency and bolsters credibility. Failing to disclose, can invite undue scrutiny, jeopardize funding or career opportunities, and could even result in legal prosecution.
In response to both the prescribed FCOI compliance requirements and recent federal notices, TCU is bringing awareness to the concerns regarding foreign influence. Therefore, in addition to our FCOI disclosure, TCU requires disclosure of any support an investigator receives that reasonably appears to be related to your institutional responsibilities including any activity related to your research that may occur over summer months or at other US or foreign institutions or laboratories. These disclosures should occur annually or ad hoc within 30 days upon discovering or acquiring a FCOI or new other support. The institutional disclosure is completed by submitting the Research Financial Conflict of Interest and Other Support Disclosure Form. The form, along with all external research that reasonably appears to be related to your institutional responsibilities should be processed through the TCU Office of Sponsored Programs
