Financial Conflict of Interest
IMPORTANT INFORMATION FOR ALL FAMU RESEARCHERS
As part of its commitment to promoting objectivity in sponsored research and in compliance with applicable federal regulations, non-federal agency guidelines, and the Financial Conflict of Interest (FCOI) in Sponsored Research policy, the Office of Research Compliance requires all investigators to submit a Financial Conflict of Interest in Sponsored Research Disclosure Form (“disclosure form”) with the proposal routing form prior to submission of the proposal to a Public Health Service (PHS) agency, including but not limited to the National Science Foundation (NSF), the National Institutes of Health (NIH), the Health Resources and Services Administration (HSRA) and other applicable private foundations/agencies to ensure the design, conduct and reporting of sponsored program/project activity will not be biased by significant financial interests or obligations of an investigator. A Research Compliance Disclosure Form is required with each grant application where Florida A&M University will be the recipient or a sub-recipient.
Who Must Disclose?
Any individual (including personnel from other institutions) who is responsible for the design, conduct or reporting of PHS, NSF, NIH and other applicable sponsored research/programs, or proposals for such funding, referred to as “Investigator.” This definition is not limited to those titled or budgeted as principal investigator or co-investigators on a proposal, and may include post-doctoral fellows, students, graduate students, collaborators or consultants. Principal Investigator agrees to submit updated forms as needed during the sponsored project award period. Any change to FCOI declaration information requires a re-submission within 30 days of change.
What are “Institutional Responsibilities”?
An Investigator’s "Institutional Responsibilities" is defined as the Investigator’s professional responsibilities on behalf of the Institution. This includes activities such as research, teaching, clinical or other professional practice, academic activities, scholarly events, institutional committee memberships, and service on panels such as Institutional Review Boards or compliance committees.
Instructions:
Investigators are required to complete a Financial Conflict of Interest in Research Compliance (FCOI) Disclosure Form. Investigators having a Significant Financial Interest that is reasonably related to the Investigators’ institutional responsibilities must also complete the Disclosure Form. The external interests and activities disclosed are assessed to determine whether they could potentially interfere with or detract from one’s Florida A&M University obligations and responsibilities. A “Yes” response in this disclosure does not necessarily mean a FCOI exists in sponsored activities.
However, without complete disclosure of the facts, a fair and reasonable assessment of a situation cannot be made. It is FAMU University’s obligation to determine whether disclosed interests and activities could directly or significantly affect University responsibilities or interests and, if so, how to manage, reduce, or eliminate the identified conflict.
FCOI disclosure requirements and the procedures for handling potential conflicts are outlined in the University’s Financial Conflict of Interest in Research Policy. The disclosure process is associated with the monitoring and review of all sponsored programs and activities; therefore, please ensure that you are aware of your ongoing responsibilities as outlined in the Financial Conflict of Interest in Research Policy.
Please answer all questions honestly and completely. If you are uncertain of whether to disclose something, it is generally prudent to disclose rather than not disclose. If you are not certain of specific information requested following an affirmative response, a reasonable estimate or explanation to the best of your knowledge is appropriate. Any change to FCOI declaration information requires a re-submission within thirty (30) days of change.
You may contact the Office Research Compliance if you have questions regarding the disclosure form: FCOI@famu.edu For additional questions related to the Financial Conflict of Interest training and CITI, please contact Dr. Tanise Jackson, Director of Research Compliance and Research Security at tanise.jackson@famu.edu
