Initial Peer Review Conflict of Interest Policy

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An essential part of ensuring research integrity is managing conflicts of interest that may bias the review of a grant application. NIH Scientific Review Officers (SROs) spend considerable time and energy identifying appropriate reviewers and managing reviewer conflicts of interest.

On Sept 26, 2011 NIH revised and made public its policy for managing conflict of interest (COI) in the initial peer review process, effective for applications submitted for the September 25, 2011 due date and beyond. NIH's policy identifies the types of roles, relationships, and financial interests that may cause conflicts of interest, and the implications for peer review.

To whom does the policy apply?

The policy applies to reviewers participating in initial peer review, for all types of grant programs, with the exception of construction grants and the Loan Repayment Program.

How does the policy define the various roles, relationships and interests?

The policy breaks down reviewer roles, relationships, and interests for each application into the following three major categories.

What is a relationship?
Major Professional Roles	Professional Relationships	Minor Professional Roles
For single project applications: PD/PI (Multi PD/PI) Senior/Key Personnel Other Significant Contributors Consultants* Collaborators* Member of Advisory Board (Discretion of SRO) Project/Site/Core of multi-component applications: Project/Site/Core Directors	For single project applications: Co-authors of research publication Collaborators* Reference letter for fellowship Speaker in conference application Referee for fellowship or career development application General letters of support MRPs in another application or project Primary appointment in same unit as individual with major role Project/Site/Core of multi-component applications: Co-authors of research publication in last 3 years Collaborators* General letters of support Member of Advisory Board (Discretion of SRO) Primary appointment in same unit as individual with major role	For single project applications: Free resources Free services Collaborator of a collaborator* Data donations to central repository or consortium Co-author of review article, position paper, professional group or conference report Multicenter network not related to application Project/Site/Core of multi-component applications: Senior/Key Personnel Other Significant Contributors Consultants Collaborators Free resources Free services Letters of support Data collection

*A consultant or collaborator who has received or could receive a direct financial benefit of any amount from an application under review, applicant institution, or PD/PI, or has received or could receive a financial benefit from the applicant institution or PD/PI that in the aggregate exceeds $10,000/year is defined as a major professional role.

What is the effect of the various roles, relationships and interests on review service?

The type of professional relationship determines which restrictions apply to each potential reviewer.

Major professional roles		Cannot serve on the Scientific Review Group (SRG)
Professional relationships		May serve on the SRG, may not participate in discussion and evaluation of the application
Minor professional roles		May serve on the SRG, may review application

How does the policy apply to me?

Case Study 1 (MS Word - 31 KB)
Case Study 2 (MS Word - 26 KB)
Case Study 3 (MS Word - 24 KB)

Want more policy details?

See Revised Policy: Managing Conflict of Interest in the Initial Peer Review of NIH Grant and Cooperative Agreement Applications.

NIH Conflict of Interest Rules: Information For Reviewers Of Grant Applications And R&D Contract Proposals - (PDF - 16 KB)

NIH pre-review certification form regarding conflict of interest for non-federal and federal reviewers of grant applications and R&D contract proposals - (PDF - 64 KB)

NIH post-review certification form regarding conflict of interest for non-federal and federal reviewers of grant applications and R&D contract proposals - (PDF - 39 KB)

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