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Financial Conflict of Interest (FCOI)

Disclosing Financial Interests

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Investigators must disclose all identified significant financial interest (SFI) to the Office of Research Compliance (ORC):

  • At least once annually
  • No later than the time of application for Public Health Service (PHS)–funded research
  • Within 30 days of acquiring or identifying a new SFI

Principal investigators must ensure that all investigators working under their direction on a research project disclose any identified SFIs prior to their participation on the project. In addition, principal investigators need to indicate, upon submission of a proposal/application to the Office of Sponsored Research, if they or any project investigators have SFI that may be related to the proposed project.

Investigators must have a complete Annual Disclosure or Initial Disclosure on file prior to submitting Disclosure Updates or Travel Disclosures.

For questions regarding what qualifies as an SFI or when to make a disclosure, contact the Office of Research Compliance.

Travel Disclosure

Investigators must disclose any identified sponsored or reimbursed travel as defined in the Financial Conflicts of Interest Policy (ORC-003) (PDF) within 30 days of the trip end. If an investigator is able to reasonably anticipate the occurrence of sponsored or reimbursed travel, they may disclose such travel up to twelve months in advance of the trip. If an advance disclosure of travel becomes inaccurate, the investigator must provide an updated disclosure within 30 days of the change. Please do not submit a Travel Disclosure unless you have submitted a complete Annual Disclosure or Initial Disclosure.

The Travel Update Tool, below, guides investigators through the process of providing the required travel information.

Disclosure Update

Investigators must disclose any identified significant financial interest (as defined in ORC-003 [PDF]) within 30 days of discovering or acquiring it. Information that must be provided to the Office of Research Compliance (ORC) varies depending on the type of SFI. Please do not submit a Disclosure Update unless you have submitted a complete Annual Disclosure or Initial Disclosure.

The Disclosure Update Tool, below, guides investigators through the process of providing the required information.

Initial Disclosure

Investigators must submit an Initial Disclosure under the following circumstances:

  • Investigators (employees, non-employees or faculty) who are new to the research institute must disclose all identified significant financial interest (SFI) to the Office of Research Compliance (ORC) during their onboarding process.
  • Investigators who have not yet participated in funded research and are planning to participate in an ongoing funded research project must disclose any identified significant financial interests (SFI) prior to participation in the research.
  • Investigators who have not yet participated in funded research and are planning to participate in a research project after funding is secured must disclose identified significant financial interests (SFI) prior to the submission of the proposal/application to the Office of Sponsored Research.

The Initial Disclosure Tool, below, guides investigators through the process of providing the required information.

Questions

For questions regarding what qualifies as an SFI or when to make a disclosure, contact the Office of Research Compliance.

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