Financial Conflicts of Interest (FCOI)
The Public Health Service (PHS) issued updated conflict of interest regulations applicable to existing and new PHS-funded investigators in effectÂ August 24, 2012Â (clickÂ here)Â note:Â All Faculty and Staff must also be in compliance with the OU Board of Regents Conflict of Interest policy which can be foundÂ here.
- PHS investigators include the Project Director/Principal Investigator, key personnel andÂ anyonedesignated by the PD/PI as critical to the design, conduct, and reporting of research.
- the PD/PI are responsible for identifyingÂ allÂ Investigators as defined by the PHS guidelines
- may include support staff
Applies to sub-investigators, sub-recipients, sub-grantees, collaborators, subcontractors, or consortium members and includes state flow-through.
PHS agencies include: HHS, NIH, CDC, FDA, AHRQ, HRSA, IHS, SAMHSA, ATSDR, ACF, & CMS
- Training requirements
- All current PHS investigators must complete the financial conflict of interest training initially and repeat every 4 years.
- The mandatory OUHSC training may be accessedÂ here.
- PHS regulations require that in order for spending to continue on active grants, all training must be completed by all investigators before the next Notice of Award for that project.
- Travel Reporting:Â If an outside organization reimburses you for travel expenses or pays your travel expenses directly, you must disclose the travel to the Office of Research
- Note:Â NIH travel is exempted and there are many other exceptions that are covered in the online training.
- Subcontracts (Subrecipients)
- Subrecipients must certify they are in compliance with PHS regulations.
- Disclosure thresholds.Â Â All Investigators must:
- Disclose ALL outside Signficant Financial Interests (SFI) related to OUHSC responsibilities based onÂ PHS SFI criteria
- Disclose new interest/changes within 30 days to the Office of Research.
- Significant financial interest threshold lowered to $5,000.
- Note:Â Â Investigators must discloseÂ allÂ Significant Financial Interests.Â The Office of Research determines whether itâs a Conflict of Interest.
- Reporting & Public Accessibility
- All Financial Conflict of Interests must be made publicly available within 5 days of request.
- Financial conflict of interests and management plans will be reported to the PHS Agency.
For more detailed information, clickÂ here.
If you have any questions, please donât hesitate toÂ contact us