Financial Conflict of Interest (FCOI)

UNC's Policy on Financial Conflict of Interest Pertaining to Sponsored Programs establishes standards to provide a reasonable expectation that work supported by externally funded awards will be free from bias resulting from financial conflicts of interest of project personnel. The UNC policy brings the university into compliance with federal requirements promoting objectivity in sponsored projects.

Prior to submitting a proposal to an external funding agency and at other times as specified in the UNC FCOI Policy and Implementing Procedures, all persons involved in the design, conduct, and reporting of the proposed project must disclose any significant financial interests they hold that  are related to their institutional responsibilities. Should any significant financial interest be deemed by the university to create a financial conflict of interest, a plan will be developed and implemented to manage or remove the conflict. In some instance, training in FCOI is required of project personnel prior to beginning work on the project.

In addition, prior to starting to work on a funded project, personnel involved in projects funded by the Public Health Service (including NIH, CDC, AHRQ, and others) must complete training on financial conflict of interest. The required Collaborative Institutional Training Initiative (CITI) training course is web-based and easily accessed. while the PHS is the only agency with the training requirement as of now, it is recommended that all investigators take advantage of the CITI training.

All investigators should be familiar with UNC's FCOI policy (found at Article 3, Part 4, Section 3-3-402(2) of University Regulations) and the Implementing Procedures in order to prepare their Significant Financial Interest Disclosures and to comply with other requirements of the policy and procedures.

The requirement for disclosure of significant financial interest also applies to sub-recipient investigators on proposals submitted to the National Science Foundation and most offices of the Public Health Service (including the National Institutes of Health). The requirement for FCOI training applies to PHS sub-recipient investigators.

If you are submitting an NSF or PHS proposal that includes subawards, the form for sub-recipient disclosures will be made available to you by OSP during the proposal development process.

Questions?

Please direct questions about the FCOI requirements and forms to Sherry May at 970-351-1910.