Policy & Compliance

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Frequently Asked Questions
Initial Peer Review Conflict of Interest Policy

Initial Posting: October 19, 2011
Last Revised: April 2, 2013

  1. Why are there different COI rules for grant reviews and technical evaluations of R&D contract proposals?

    Technical evaluations of R&D contract proposals are subject to federal rules for acquisitions that do not apply to grant reviews.  


  2. Do the policies only apply to those participating in initial peer review or technical evaluation?
    Yes. Members of NIH National Advisory Councils or Boards, who participate in the second level of peer review, fall under the ethics rules [http://ofacp.od.nih.gov/ethics/index.asp] associated with Special Government Employees.
  3. Which relationships constitute a conflict of interest in initial peer review?

    Generally speaking, conflicts of interest in initial peer review or technical evaluation result from one or more of the following scenarios:

    • The potential for financial benefit
    • Employment
    • Major Professional Roles in the work proposed
    • Professional associations with individuals listed with Major Professional Roles in the work proposed
    • Membership on a Standing Study Section or Recurring Special Emphasis Panel
  4. Which relationships do NOT constitute a conflict?
    • Provision of resources or services that are freely available to the entire scientific community
    • Co-authorship of a review article, position paper, professional group or conference report
    • Data donations to a central repository or consortium
    • Institutional membership in a multicenter network unrelated to the application under review
  5. Can federal staff serve as reviewers?
    Yes, certain Federal staff may serve as reviewers.  Federal employees serving as reviewers in NIH peer review also must comply with the ethics rules of their office or agency.
  6. Who is responsible for identifying and declaring conflicts of interest in peer review?

    Reviewers are responsible for declaring COI, and SROs are responsible for explaining the rules to their reviewers and screening for COI to the extent possible.Unlike members of NIH Advisory Councils or Boards, reviewers in the initial level of NIH peer review are not appointed as Special Government Employees and do not submit financial disclosure forms.  Therefore, SROs are not in the position to collect financial information from reviewers, but can ask about professional relationships and roles and make determinations about potential bias in the initial peer review process.

  7. What is the cutoff on the number of authors that make a publication “multi-authored”?
    The NIH policy does not specify a specific number of authors that renders a publication “multi-authored”.  Of greater significance are the roles that the authors played in the research that is reported in the publication.  The SRO must also be aware of the appearance of a conflict of interest.
  8. Are training faculty listed on a training grant application considered to have Major Professional Roles?
    For training grant applications, the Principal Investigator(s) or Program Director(s), and members of a curriculum committee or Advisory Committee, and any other personnel who will be involved in administration of the award or training program have Major Professional Roles. Therefore, they cannot serve on the review panel.  However, faculty who could potentially gain a student or fellow supported in their laboratories on the training award have Professional Relationships, and therefore can serve on the panel but cannot review the application in question.
  9. When is a collaborator or consultant considered to have a Major Professional Role in a project or application?

    An individual with a Major Professional Role contributes to the scientific development or execution of the project in a substantive, measurable way, whether or not compensation is requested.  In addition, the fact that an individual is named in an application can create a COI.

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This page last updated on October 19, 2011 
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