Conflict of Interest

Conflict of Interest

CUNY’s Conflict of Interest (COI) policy establishes standards to protect against the possibility that a conflicting interest will bias the design, conduct, reporting or review of research at the institution. The information provided here summarizes key CUNY policies and procedures as a reference for John Jay researchers; please refer to the CUNY website for full details and current information on CUNY’s Conflict of Interest policy.

Training Requirements: 

Investigators engaging in research related to any PHS funded grant or contract are required to complete online COI training provided by CITI.  The John Jay College Conflicts Officer (CCO) may require certain John Jay researchers engaging in research that is not PHS funded to complete training as well. 

Training is available through the Collaborative Institutional Training Initiative (CITI),

Investigators should submit a copy of the CITI COI Completion Report to the CCO and attach it to any PHS-funded grant proposal or contract submitted to the Office of Sponsored Programs. Detailed requirements and instructions are available here.

Significant Financial Interest Disclosure Process:

When a PI submits a grant proposal or application, each investigator must complete a Significant Financial Interest (SFI) Disclosure Form and submit it to the Office for Sponsored Programs (OSP) and the CCO. CUNY uses separate Significant Financial Interest (SFI) Disclosure Forms for PHS Funded Research and for Research NOT Funded by PHS

If the investigator answers ‘yes’ to any of the questions on the SFI Disclosure Form, then s/he must also complete the relevant CUNY Significant Financial Interest Supplement Form and submit it to OSP and the CCO.

Each investigator must submit an updated CUNY SFI Disclosure form to OSP and the CCO:

  • annually if PHS funded
  • prior to submission of annual progress reports regardless of funding, and
  • within 30 days of any material change in the previously disclosed SFI or discovering/acquiring a new SFI regardless of funding.

PHS Agencies:

  • Agency for Healthcare Research and Quality (AHRQ)
  • Agency for Toxic Substances and Disease Registry (ATSDR)
  • Centers for Disease Control and Prevention (CDC)
  • Food and Drug Administration (FDA)
  • Health Resources and Services Administration (HRSA)
  • Indian Health Service (IHS)
  • National Institutes of Health (NIH)
  • Substance Abuse and Mental Health Services Administration (SAMHSA)


Conflict of Interest in Human Subjects Research:

The IRB evaluates the impact of any financial or professional conflicts of interest disclosed by the research team on the protection of research participants. The IRB may require disclosure of conflicts of interest to research participants. Additionally, financial conflicts of interests, as defined in CUNY’s Conflict of Interest Policy, will be forwarded to the CUNY Conflicts Committee for review and oversight in accordance with the Policy.

John Jay College Conflicts Officer (CCO):

Each CUNY College has a designated Conflicts Officer (CCO) who is responsible for implementing CUNY’s Conflict of Interest policy, for promoting the need to disclose significant financial interests to faculty and staff at their College, and for reviewing all disclosures in accordance to this policy.  

John Jay CCO:    Eric Doering
                               Research and Legal Compliance Associate

CUNY Conflict of Interest Policy:

Resources for Thinking about Conflicts of Interest and Commitment: