New NSF requirements for conflict of interest disclosure


February 21, 2023

Effective Jan. 30, 2023, the National Science Foundation amended its definition of “significant financial interest” to include “private equity” and “venture or other capital financing.” This new definition means that faculty with NSF funding who also have equity and/or an ownership interest in a non-publicly traded company may be required to disclose additional information about the investors in the non-publicly traded company. The requirement to disclose will depend on whether the financial interest in the company or the company’s activities reasonably appear to be affected by NSF funding or proposed NSF funding.

The Office of Research Integrity is monitoring these changes and reaching out directly to faculty who may be impacted by these new requirements. Additionally, ORI is working to update internal GW COI documents, including the project specific, transactional conflicts of interest/conflicts of commitment disclosure form, as appropriate.

For more information, please contact the Office of Research Integrity.

Updated Proposal and Award Policies and Procedures Guide, https://nsf-gov-resources.nsf.gov/2022-10/nsf23_1.pdf

The term “significant financial interest” means anything of monetary value, including, but not limited to, salary or other payments for services (e.g., consulting fees or honoraria); equity interest (e.g., stocks, stock options, private equity, or other ownership interests); venture or other capital financing, and intellectual property rights (e.g., patents, copyrights, and royalties from such rights).