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To prevent program officers or other extramural staff, peer reviewers, or Council members who may have a real or apparent conflict of interest with an investigator or applicant organization from participating in a peer review.
A conflict of interest in peer review exists if a reviewer or staff member has a real or apparent conflict of interest with an investigator or an organization that has submitted a grant application or contract proposal he or she is supposed to review or manage. It is important that reviewers consult the scientific review officer (SRO) in charge of the review when there is any question about their participation in a meeting.
NIH Conflict of Interest Guidelines. A participant must leave the room for the following reasons if the participant, a close relative (e.g., spouse, minor child, sibling, or parent), or partner (e.g., close professional associates or other colleagues):
- Has a financial interest in the outcome of an activity such as peer review
- Serves as an officer, director, member, owner, trustee, expert, advisor, consultant (with or without compensation), or employee of an applicant or other organization that would be affected by his or her decision.
- Is negotiating or has an arrangement for prospective employment with an applicant or other organization that would be affected by his or her decision
- Conducts research or other professional activities with an applicant or has done so within three years of the review date
Participants are urged to avoid any actions that might give the appearance of conflict of interest, even if they believe there may not be an actual conflict. For example, a reviewer should not participate in the deliberations on a grant application or contract proposal from a student, teacher, or a close personal friend.
If an applicant names a person from another institution in the application, that named person may not participate in the application's review if he or she is:
- Collaborating with the applicant's research (a direct conflict)
- Cofunded with other investigators or key personnel who are collaborating with the applicant's research (an indirect conflict)
However, the named person will be permitted to review other applications from the applicant's institution as long as he or she has no other conflicts of interest (direct or indirect) with the other applicants.
Components of a large or multi-component organization that function as separate organizations. NIH may determine that a peer reviewer selected from a component does not have a conflict of interest with the review of an application from another component when both of the following conditions exist:
- Components are independent and act as separate organizations
- Reviewer does not have responsibilities at one component of the organization that significantly affect the other component
For more information, see Managing Conflict of Interest in the Initial Peer Review of NIH Grant and Cooperative Agreement Applications and NIH Conflict of Interest, Confidentiality and Nondisclosure Rules: Information for Reviewers of Grant Applications and R&D Contract Proposals.
NIH has established a conflict of interest threshold of $10,000 for extramural researchers serving on NIH scientific peer review panels that evaluate research applications and proposals. The $10,000 financial threshold includes all sources of financial benefit, including honoraria, fees and stock holdings; both currently held assets and those accruing over a 12-month period. It includes interests held by immediate family members of the reviewer.
A reviewer with a financial or other interest worth $10,000 or more in the application to be reviewed will be disqualified from the review. The NIH director may make exceptions if there are no other appropriate means of securing expert advice or the conflict is not substantial enough to bias the review.
- See the Council Conflict of Interest Statement for conflict of interest procedures.
Scientific Review Officers
- Identify and manage reviewers and NIH staff conflict
- Maintain a conflict of interest list
- Ensure reviewers and NIH staff who have a conflict of interest are not present during the discussion of an application or proposal
- Provide guidance on staff conflict of interest issues
- If you coauthored a paper during the previous three years with an investigator
- You must defer funding decisions for three years.
- You cannot participate in source selection meetings as a selecting official.
- If you plan to attend a peer review
- Review the Conflict of Interest (COI) list and Pre-COI Certification form provided by the SRO
- Discuss potential conflicts with the SRO
- Sign the Pre-COI Certification form and return it to the SRO before the peer review.
- When you attend a meeting, do not take notes that would identify reviewers and do not discuss individual reviewer comments with investigators or individual applications with reviewers.
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- FAQ on Revised COI Policy
- Financial Conflict of Interest
- Initial Peer Review Conflict of Interest Policy
- NIH Staff (Co-) Authorship of Publications from NIH Extramural Awards