A newly updated policy on Financial Conflicts of Interest Related to Research and Sponsored Programs is effective January 1, 2020.
The updated policy includes significant changes. These are the most important:
- The policy applies to all University Research and Sponsored Programs – regardless of sponsor. This means that there is now one policy, one disclosure form, and one set of disclosure requirements. The policy applies to any research activity supported by university funds, regardless of source (“University Research”). University Research includes research activities that are not supported through Sponsored Program funds administered by the Office of Research and Sponsored Programs (ORSP) or the internal grant program administered by the Office of the Vice President of Research (VPR). For Sponsored Program activities that are supported by funds administered by the ORSP or the OVPR, there are no longer separate disclosure requirements for U.S. Public Heath Service (PHS)-Agency funded sponsored programs, other than PHS rules on acceptance of meals and travel expenses.
- The policy requires Project Personnel to disclose their Significant Financial Interests (SFIs), and those of their Family, that are Related to their research at the following times:
- The dollar value threshold requiring disclosure of Related SFIs is now $5,000.
- For publicly traded External Entities: Project Personnel are required to disclose if the present value of their/their Family’s equity interest PLUS total compensation received directly/by their Family in the 12 months preceding the disclosure totals $5,000 or more.
- For non-publicly traded External Entities: Project Personnel are required to disclose if they/their Family has received total compensation of $5,000 or more in the 12 months preceding the disclosure AND/OR they/their Family holds any equity interest, regardless of value.
All faculty and staff who engage in University Research are responsible for understanding their disclosure obligations pursuant to this policy and for notifying their Department Chair/direct supervisor prior to engaging in University Research if they have a related SFI to disclose.
Research Integrity and LTS are in the process of developing a new electronic system to enable faculty and staff to easily submit disclosures electronically. The new system is expected to be available in the Spring of 2020. In the meantime, ORSP and OVPR will continue to solicit disclosures with Sponsored Project proposals/awards.
- Policy: Financial Conflicts of Interest Related to Research and Sponsored Programs
- fCOI Training Document / PPT file
Naomi Coll, MPH, CPH, CIP
Director of Research Policy and Compliance
- fCOI Glossary of Terms
- Sponsored Program Proposal-Based Disclosure Form
- Public Accessibility of a COI Related to Public Health Service-Funded Research
- Managing Conflicts of Interest When Investigators Have Financial Interests or Operational Roles in Companies Sponsoring University Research
- Faculty Ownership and Operation of Businesses, Consulting, and Other External Professional or Business Activities