Financial Conflict of Interest Disclosure

Financial Conflict of Interest (FCOI) disclosures are collected regularly at PSU from faculty with funded projects. Federal regulations require PSU to have FCOI disclosures on file for each principal investigator and designated key personnel. As relationships between Portland State researchers and community partners continue to grow, it is important 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--must be disclosed, reviewed, and managed in accordance with state and federal regulations and PSU policy.

Submitting a Financial Conflict of Interest Disclosure

Use the link above to complete a disclosure. PSU 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 an FCOI 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.

PSU FCOI Policy

Contact Us

FCOI questions or requests need to be directed by email to fcoi@pdx.edu or by phone at 503-725-4288.

Financial Conflict of Interest FAQs

What is a Financial Conflict of Interest?

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.

When will I need to submit my disclosure?

  • Any new researchers are required to submit an FCOI disclosure at the time of submission of proposals for federal funding to PHS or NSF.

  • All existing researchers are required to complete the annual FCOI disclosure.

  • All researchers are required to submit an updated FCOI disclosure immediately as significant changes occur, such as the obtaining of a new significant financial interest.

I am applying for and/or receiving PHS funding. How can I satisfy my FCOI training requirement?

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.

Where can I get help with submitting my disclosure?

Please contact Research Integrity & Compliance at fcoi@pdx.edu or call 503-725-4288 and describe the problem in detail. We will do our best to troubleshoot the issue with you.

What is a management plan and do I need one?

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. Review or download our FCOI management plan template, and please contact us if you have questions.

What do all these acronyms stand for?

FCOI: Financial Conflict of Interest

NIH: National Institutes of Health

NSF: National Science Foundation

PHS: Public Health Service

PI: Principal Investigator

PIAF: Proposal Internal Approval Form

RGS: Research & Graduate Studies

SBIR/STTR: Small Business Innovation Research/Small Business Technology Transfer

SFI: Significant Financial Interest

What funding organizations require adherence to PHS FCOI regulations?

According to the U.S. DHHS Organizational Chart, the following organizations require compliance with PHS regulations (please note that this list is not exhaustive):

U.S. Public Health Services Agencies include:

    • Agency for Healthcare Research and Quality (AHRQ)

    • Centers for Disease Control (CDC)

    • Food and Drug Administration (FDA)

    • Health Resources and Services Administration (HRSA, including

      • Office of Rural Health Policy

      • Office of Women's Health

    • Indian Health Services (IHS)

    • National Institutes of Health (NIH), including

      • National Cancer Institute

      • National Institute on Aging

      • National Institute on Alcohol Abuse and Alcoholism

      • National Institute of Child Health and Human Development

      • National Institute on Drug Abuse

      • National Institute on Mental Health

      • National Institute of Environmental Health Sciences

    • Office of Global Affairs (OGA)

    • Office of the Assistant Secretary for Health, including

      • Office of Adolescent Health (OAH)

      • Office of Disease Prevention and Health Promotion (ODPHP)

      • Office of HIV/AIDS and Infectious Disease Policy (OHAIDP)

      • Office of Minority Health (OMH)

      • Office of Population Affairs (OPA)

      • Office of Research Integrity (ORI)

      • Office on Women’s Health (OWH)

    • Office of the Assistant Secretary for Preparedness and Response, including

      • Office of the Biomedical Advanced Research and Development Authority (BARDA)

      • Office of Emergency Management (OEM)

    • Substance Abuse and Mental Health Services Administration (SAMHSA)

Non‐PHS organizations which have either adopted the PHS regulations or follow other COI regulations:

    • Alliance for Lupus Research

    • Alpha-1 Foundation

    • American Asthma Foundation

    • American Cancer Society

    • American Heart Association

    • American Lung Association

    • Arthritis Foundation

    • California Institute for Regenerative Medicine (CIRM)

    • CurePSP

    • Environmental Protection Agency

    • Juvenile Diabetes Research Foundation

    • Lupus Foundation of America

    • Patient-Centered Outcomes Research Institute

    • Susan G. Komen Foundation

Because there may be changes, if the agency you are interested in is not listed above or you are unsure if it is a PHS agency, please check with your funding source or reach out to Research Integrity & Compliance Program staff at fcoi@pdx.edu.