Sanctions for non-compliance with the Financial Conflict of Interest related to Research policy

Cornell University and its members are committed to conducting research in a manner that ensures the integrity of the research process and maintains the public trust and that of sponsors in the integrity and credibility of its faculty, staff, and research programs. This commitment requires the university to ensure that research results are not biased by the external commitments and financial interests of persons who are responsible for the design, conduct, reporting, or direct administration of university research. Compliance with the policy concerning financial conflicts of interest in research is a critical component of maintaining that commitment.

Accordingly, Principle 11 of FCOIRR Policy 1.7 establishes the expectation of compliance with the policy as follows: “Persons subject to this policy are required to report fully and accurately their external commitments and financial interests, and to comply with any plans developed to manage their real or apparent financial conflicts of interest. Disciplinary measures and sanctions will be imposed when they fail to report as required or when they fail to comply with management plans.”

New this year: Please note that in order to comply with expanded federal requirements regarding activities with foreign entities, this year, depending on your answers to the survey questions, you may be required to provide supplemental information about your engagements outside of Cornell. If this is the case, instructions will be provided by the COI office and the deadline for completion will be extended appropriately.

Individuals who do not submit their reports and supplemental surveys if required on time will be subject to sanctions as follows:
  • An individual who has not completed and submitted the Annual Report cannot be named as a PI, Co-PI or Key Personnel on any new proposal submitted or new award received, or on any research protocols (IRB, IACUC, IBC). Colleges and Grant and Contract Officers (OSP, CVM, CALS) will not submit any proposals, and OSP will not accept any awards, until the individual produces evidence that they have complied, or they are removed from the proposal or award.
  • Non-compliant individuals will not be eligible to enter into technology transfer agreements.
  • In cases where a non-compliant individual is the Principal Investigator (PI) on an active award, the individual’s department and college will identify an alternate PI and request approval from the funding agency for the proposed change. If approval is not granted, the award will be terminated and any resulting costs will be covered by the original PI’s discretionary funds, and then department or college funds, if needed.
  • Any salary or stipend of the non-compliant individual that is being charged to a sponsored award will be stopped as of 10 AM on May 10, 2021. For the entire period that the individual is non-compliant, and for the period of time that it takes the COI Committee to review and act on any possible management plan actions, only non-sponsored funds may be used to cover the salary or stipend. Retroactive salary charges to any sponsored award will NOT be allowed for the period of non-compliance.
  • If the individual is key personnel on a sponsored award funded by a PHS Agency (NIH, CDC, FDA and others), the non-compliance will be reported to the funding agency.
  • Future annual salary increases will not be paid for the pay periods during which the individual remains non-compliant. Unpaid amounts will not be reimbursed.
  • Any suspension of research activities and associated salary will be undertaken in accordance with the applicable university policies and codes.
  • If the individual has a temporary assignment at Cornell, such as a Visitor, Adjunct or Courtesy appointment, that appointment will be terminated.