Financial Conflict of Interest in Research
The FAU Financial Conflict of Interest (FCOI) Committee exists to ensure that all potential financial conflicts of interest related to FAU research are managed appropriately. The FCOI Committee is a faculty led committee that reviews disclosures made by researchers, identifies conflicts of interest, and helps researchers develop plans to manage those conflicts.
More details can be found in the Financial Conflict of Interest (FCOI) Policy.
All FCOI Disclosures should be made through Novelution.
FCOI Disclosure is a two-step process: Significant Financial Interest Disclosure and Project Specific Disclosure.
This disclosure should be completed annually by any key personnel for a sponsored research project who have significant outside financial interests. You can edit your SFI in Novelution by selecting 'My SFI Disclosure' from the FCOI drop down at the top. Your SFI should be updated whenever your interests change.
When funding for a project is awarded, researchers who have disclosed outside interests in an SFI will be asked to complete a Project Specific Disclosure for each sponsored project. The PSD asks the researcher to relate the goals and activities of their disclosed outside interests to the goals and activities of the sponsored research project in question. These disclosures should be filled out in full even if the outside interest is not directly related to the specific research project.
All key personnel must complete the CITI FCOI training.
- Log in to citiprogram.org.
- Click 'My Courses' and 'View Courses' for Florida Atlantic University.
- At the bottom of the page, select 'Add a Course.'
- Select option 4, 'Conflict of Interest (COI)' and click 'Next.'
- The Conflict of Interest Stage 1 course is now added to your account.
- Select 'Start Now' to begin the course.
- If you have already completed Conflict of Interest Stage 1, and the expiration date is within the next 90-days, the same steps will enroll you in the Stage 2 Refresher course.
If you do not already have a CITI account, you first need to create an account and select Florida Atlantic University as your affiliation.
All Disclosures are reviewed by the FCOI Committee to identify potential financial conflicts of interest. To ensure a quick review, please include enough information in your disclosures to allow the Committee to make an independent determination regarding the potential for conflict of interest.
SBIR and STTR funded projects may have different review requirements.
January 21, 2026
February 18, 2026
March 18, 2026
April 15, 2026
May 20, 2026
June 17, 2026
F.A.Q.
A financial conflict of interest exists when an investigator's significant financial interest could affect the design, conduct, or reporting of research. Any potential financial conflict of interest must be managed in order to ensure the integrity of the research, the safety of any research participants, and the proper development of any intellectual property.
A Significant Financial Interest includes any entity where the researcher's equity and remuneration combined exceed $5000, any non-publicly traded entity in which the researcher has any equity, or any intellectual property, patents, or copyrights. The SFI can be updated in Novelution at any time. More information can be found in the Financial Conflict of Interest (FCOI) Policy.
Whose interests must be disclosed?
You must disclose Significant Financial Interests for:
- Yourself
- Your spouse
- Your dependent children
SFI disclosures should be updated:
- Annually
- Prior to submitting proposals for internal or external funding
- Within 30 days of acquiring a new SFI
- Within 30 days of joining a research project already in progress
- Within 30 days of any reimbursed or sponsored travel
Significant Financial Interest does NOT include:
- remuneration from FAU
- remuneration paid to a researcher’s family by any entity that would not reasonably appear to be related to any area of the investigator’s institutional responsibilities
- remuneration from authorship of academic or scholarly works
- remuneration from seminars, lectures, or teaching engagements sponsored by governmental agencies or institutions of higher education within the U.S.
- investment by a mutual fund, pension fund or other investment fund where the researcher does not control investment decisions
Novelution will prompt researchers who have disclosed outside interests in an SFI disclosure to complete a PSD when a sponsored research project in which they are key personnel is funded. A PSD must be completed for each project individually. This disclosure must be submitted and reviewed before funds can be released.
The PSD should serve as a record of all information required by the FCOI Committee to make an independent determination as to the potential for a financial conflict of interest. Please address the following questions for each outside interest:
- What is the goal of your outside interest?
- What is your role in the outside interest?
- What is the goal of your sponsored research project?
- What is your role in the sponsored research project?
- Describe any way that your outside interest is directly related to your sponsored research project.
- Describe how the goals of your outside interest and the goals of your sponsored research project do or do not indirectly overlap or conflict.
- Describe any steps you have taken to ensure the objectivity and integrity of your research given your outside interest.
A financial conflict of interest can still exist when the outside financial interest is not directly related in the research project. Describe the goals of the research projecty and the goals of the outside interest in full in each PSD.
Federal Regulations
- NIH Grants & Funding FCOI Requirements
- Department of Health and Human Services Final Rule 42 CFR Part 50 and Part 90
- eCFR 42 CFR Part 50 Subpart F
Questions can be directed to:
C. Elisa Gaucher, Associate Vice President for Research Integrity,
egaucher@fau.edu,
or Miriam Campo, Associate Vice President for Sponsored Programs,
campom@fau.edu