NEWS & UPDATES
Submitting your Annual FCOI Disclosure
All 2015-2016 Annual Financial Conflict of Interest (FCOI) disclosures are due by February 1, 2016. Federal regulations require PSU to have FCOI Disclosures on file for each principal investigator and their designated senior research staff.
To complete your FCOI disclosure follow this link.
Important Dates and Deadlines for 2015-16 Disclosure
Financial Conflict of Interest questions, requests and submissions should be directed by email to firstname.lastname@example.org.
Other Conflict of Interest contacts are listed here.
As relationships between Portland State researchers and community business partners continue to grow, it is important that PSU maintain high research integrity standards. Therefore, any potential for conflict of interest--where an individual's financial or personal considerations may affect or appear to affect their PSU activities related to externally sponsored programs--is disclosed, reviewed, and managed in accordance with state and federal regulations and PSU policy.
The institutional annual disclosure process requires Principal Investigators and other individuals who meet the definition of an "investigator" under the Financial Conflict of Interests regulations, (responsible for the design, conduct or reporting of research), and who are included on submitted proposals to PHS or NSF or who have externally funded research projects to complete a Financial Conflict of Interest disclosure. This disclosure must be completed no later than the day of submittal for PHS and NSF proposals and during the annual disclosure process for all other externally funded projects. Updated disclosures must be completed within 30 days for significant changes such as new significant financial interests.
The NIH (National Institutes of Health) requires that research institutions uphold "standards that provide a reasonable expectation that the design, conduct, and reporting of research performed under NIH grants or cooperative agreements will be free from bias resulting from Investigator financial conflicts of interest."
A financial conflict of interest occurs when there is a divergence between an individual’s private interests and his or her professional obligations to the University such that an independent observer might reasonably question whether the individual’s professional actions or decisions are determined by considerations of personal gain. Potential and actual financial conflicts of interest depend on the situation and both must be managed accordingly.
All Principal Investigators and all others designated as an "investigator" by the Principal Investigator will need to take either take the federal tutorial or alternatively, the COI modules in CITI may be completed (be sure to find the section describing FCOI training). Training is required of all new and existing federally-funded researchers, and must be re-taken every four years.
Be sure to read and follow the instructions at the beginning of the survey. However, if you have trouble with the online disclosure system, try one of the following options:
I already know that I will disclose a Significant Financial Interest (SFI) this year. What information do I need to have before I start the online survey?
If you know that you will be disclosing an entity with which you have a significant financial interest, you will need to report the following information, so be sure to have it ready.
For PHS & NSF funded research:
You will have the option to upload .doc or .pdf files for the travel information and names of investigators, so those may be prepared in advance.
If you have PHS funding, we will need to know whether you also have funding from NSF, as regulations require us to communicate with NSF in the event of an unsatisfactorily managed FCOI.
If it is determined that your significant financial interests result in an FCOI, you may need a management plan. Typical management plans involve agreements about facilities, students, human subjects research, institutional vs. private work activities, committee/community service roles, and any other relevant topics. You can review our management plan template here. Please contact us if you have questions.
FCOI: Financial Conflict of Interest
NIH: National Institutes of Health
NSF: National Science Foundation
ORI: Office of Research Integrity
PHS: Public Health Service
PI: Principal Investigator
PIAF: Proposal Internal Approval Form
RSP: Research and Strategic Partnerships
SBIR/STTR: Small Business Innovation Research/Small Business Technology Transfer
SFI: Significant Financial Interest
According to the U.S. DHHS Organizational Chart and the Catalog of Federal Domestic Assistance, the following organizations require compliance with PHS regulations. (Please note that this list is not exhaustive.)
U.S. Public Health Services Agencies include:
Non‐PHS organizations which have either adopted the PHS regulations or follow other COI regulations:
Because there may be changes, if the agency you are interested in is not listed above and you are unsure if it is a PHS agency, etc., please check with your funding source or the Office of Research Integrity.
As of August 2012, federal PHS (Public Health Service) regulations regarding financial conflict of interest underwent significant changes. As a recipient of federal funding, Portland State University was required to comply with these new disclosure guidelines.
Research Integrity >