Financial Conflict of Interest in Research

compass pointing toward integrity

On August 24, 2012, the Department of Health and Human Services under 42 CFR Part 50 and Part 94 required all investigators who are involved in the design, conduct or reporting of research to adhere to revised disclosure requirements. See this link. FAU responded with implementation of the required policy and disclosure forms including offering training through the Collaborative Institutional Training Initiative (CITI).

The revised key areas included: the expanded definition of a Significant Financial Interest which includes:

  • Lowering the disclosure threshold to $5,000
  • Expanding the extent of investigators' disclosure of information to institutions regarding their Significant Financial Interests
  • Broadening an institution's management of identified Financial Conflicts of Interest.

Florida Atlantic University's Financial Conflicts of Interest in Research policy provides guidelines to promote objectivity in research while establishing standards to ensure that the design, conduct, and reporting of research funded by extramural sponsors will not be biased by any conflicting financial interest of an Investigator.

FCOI Meeting Dates

Meetings are conducted on the third Wednesday of each month unless otherwise noted. Dates are subject to change.

January 22, 2020
February 26, 2020
March 25, 2020
April 22, 2020
May 27, 2020
June 24, 2020
July 22, 2020
August 26, 2020
September 23, 2020
October 28, 2020
November 18, 2020
December 16, 2020

Guide to requirements


The following information is provided to you, our researchers, to guide you in the requirements of the federal requirements to disclose your significant financial interests.

Policies, Procedures and Guidance  

The Division of Research recognizes that actual or perceived conflicts of interest may occur in the normal conduct of research and other activities and therefore it is essential that investigators disclose their and their family members' financial interest related to research that they are involved in. Only after disclosure of a significant financial interest can the University make an informed judgment about a particular activity and require the appropriate oversight, limitations or prohibitions in accordance with applicable federal, state or university regulations.

Disclosure Process  

The Division of Research requires that all principal investigators, co-PIs and key personnel follow federal regulations, and complete a disclosure of significant financial interests (SFI):
  • Proposal-Related Disclosures: Prior to submitting proposals for internal or external funding. The significant financial interest (SFI) disclosure forms should be completed and signed by all key personnel and uploaded into grantsERA as part of the complete proposal package.
  • Ad Hoc Disclosures: Within 30 days of joining a research project already in progress or within 30 days of acquiring a new SFI. The significant financial interest (SFI) disclosure forms should be completed, scanned, and e-mailed to the Proposal and Contract Administrator assigned to the lead PI's college.
  • Travel Disclosures: Within 30 days of any reimbursed or sponsored travel undertaken by the Investigator related to his or her Institutional Responsibilities (over $5,000)
  • Annual Disclosures: Annually, significant financial interest (SFI) disclosure forms should be completed, scanned, and e-mailed to the Proposal and Contract Administrator prior to the issuing of continuing funds.

Disclosure of a Significant Financial Interest  

This form is required for assessment of Conflict of Interest, please read information below:

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A disclosure for Significant Financial Interest will be filed by each investigator (PI, co-PI and key personnel) upon submission of a funding proposal to Sponsored Programs. Upon notice of award, any positive disclosure for Significant Financial Interest will be forwarded with all applicable information, i.e. disclosure, abstract, scope of work, research strategy, to the Financial Conflict of Interest (FCOI) Committee. The Division of Research facilitates the FCOI faculty committee charged with ensuring that significant financial interests of FAU researchers (PIs, Co-PIs and key personnel) do not compromise their objectivity in:

a) Defining, conducting or reporting research activities; b) Protecting the welfare of research participants; or c) Developing intellectual property. The FCOI committee will determine whether a financial interest with an external entity (or travel sponsored by an external entity if travel disclosure is required) is related to the particular research project on a case-by-case basis.

If the FCOI committee determines that a significant financial interest (or travel sponsored by an external entity when travel disclosure is required) is reasonably related to an investigator's research-related responsibilities (design, conduct or reporting of such research) it will next determine whether the Investigator will be required to eliminate or manage the Financial Conflict of Interest, as appropriate.

A Financial Conflict of Interest may be eliminated by divestiture of Equity Interests; termination of the relationship that gives rise to the Significant Financial Interest (such as consulting); abandoning the proposal; terminating the sponsored project; or other similar measures.

If the Investigator does not want to eliminate a Financial Conflict of Interest or the appearance of a Financial Conflict of Interest and FCOI committee determines that it can be managed, the Investigator will work with the FCOI committee to develop a written management plan. This management plan will remain in place for as long as the grant award is active or until there is a change in the investigators SFI disclosure status.

Training  

The Federal regulations require mandatory training, and the Division of Research requests that such training be completed within 30 days of a proposal submission. Effective January 1, 2016, account set up for all funded awards, regardless of funding source, will not proceed without completion of the required training component.

FAU adopted the Collaborative Institutional Training Initiative (CITI) Conflict of Interest training module to fulfill this mandatory training requirement. This training, once completed, will remain current for three years and will require a refresher course thereafter.

Access to the training module is available on: http://www.citiprogram.org

Once you are registered access your CITI account and follow steps to locate training:

  • Log in to CITIprogram.org
  • Click Main Menu / My Courses and select Add a Course
  • Scroll down to Question 4 'Conflicts of Interest' and check "Yes"
  • Note that Question 6 is mandatory so you must answer that to continue
  • Click 'Submit'
  • The Conflict of Interest course Stage 1 is now added to your account
  • If you had already completed your Conflict of Interest Stage 1 and it has or is within the 90-day window to expire, these steps will provide you the Stage 2 Refresher course

Note: If you do not already have a CITI account, you first need to create an account and select Florida Atlantic University as your participating institution.

Federal Regulations  

The federal requirements are intended to promote objectivity in research by establishing standards that provide a reasonable expectation that the design, conduct, and reporting of sponsored research will be free from bias resulting from Investigator financial conflicts of interest.

For more information see:


Questions can be directed to:

C. Elisa Gaucher, Assistant Vice President for Research Integrity, egaucher@fau.edu,
or Miriam Campo, Director of Sponsored Programs, campom@fau.edu