Financial Conflict of Interest in Research
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 DatesMeetings are conducted on the third Wednesday of each month unless otherwise noted. Dates are subject to change.
January 20, 2021
February 17, 2021
March 17, 2021
April 21, 2021
May 19, 2021
June 16, 2021
July 21, 2021
August 18, 2021
September 15, 2021
October 20, 2021
November 17, 2021
December 15, 2021
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.
- 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.
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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.
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.
For more information see:
Questions can be directed to:C. Elisa Gaucher, Assistant Vice President for Research Integrity, firstname.lastname@example.org,
or Miriam Campo, Director of Sponsored Programs, email@example.com