Financial Conflict of Interest
Sponsors of external grants and the public have an expectation that grant-funded research, educational, and other activities will be designed, conducted, and reported in such a way that they are free from any bias that might result from financial conflicts of interest of the project personnel.
Federal regulations mandate that applicants obtain disclosures of significant financial interests from individuals involved in externally funded projects to determine whether whose interests constitute financial conflicts of interest and if so, to manage conflicts in a way that promotes objectivity in the sponsored activities.
Before UNC submits a proposal to an external sponsor and at other times as specified in the UNC FCOI Policy and Implementing Procedures, the Principal Investigator or Project Director and all other investigators-individuals responsible for the design, conduct, or reporting of the project- must disclose any significant financial interests that could be construed as conflicting with their role in the project.
In additon, 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 the University Regulations) and the Implementing Procedures in order to prepare their Significant Interest Disclosures and to comply with other requirements of the policy and procedures.
The requirement for disclosure of significant financial interest also applies to subrecipient 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 subrecipient investigators.
If you are submitting an NSF or PHS proposal that includes subawards, the forms for subrecipient disclosures will be made available to you by OSP during the proposal development process.
Please direct questions about the FCOI requirements to Laura Martin, laura.martin@unco.edu
