Financial Conflict of Interest (FCOI) and Outside Activities
As relationships between academia and private industry continue to grow, it is essential that financial and other relationships with external and internal entities do not create situations that may seem to be in conflict with the values of free and unbiased scientific inquiry.
All UWF employees are required to annually disclose outside activities as per University policy and Florida law. This requirement can be met by submitting the UWF Outside Activity Form. Furthermore, certain sponsors of research require an additional disclosure of Significant Financial Interests (SFI) prior to proposal submission annually and within 30 days of acquisition or discovery. This requirement is satisfied through the submission of the Financial COI Disclosure Dynamic Form by all investigators for these sponsors.
The Financial Conflict of Interest Form
The terms investigator and significant financial interest, as used in the Financial COI Disclosure Dynamic Form, are defined below as per 42 CFR 50.603.
Investigator is defined as the principal investigator, co-principal investigator, or any other person responsible for the design, conduct, or reporting of the proposed or funded research or educational activities. For the purpose of determining a Significant Financial Interest, an "investigator" also includes an employee's spouse/partner, dependent children.
Significant Financial Interest (SFI) Interest is one or more of the following financial interests of the Investigator that reasonably appears to be related to the investigator’s institutional responsibilities.
A Significant Financial Interest is:
- salary or any other payments for services not otherwise identified as salary,
- consulting fees,
- paid authorship,
- equity interests, such as stocks and stock options,
- intellectual property rights, such as patents, copyrights, and royalties.
A Significant Financial Interest is not:
- salary or remuneration from the University;
- income derived from seminars, lectures or teaching engagements sponsored by public or nonprofit entities;
- income derived from service on advisory committees or review panels for public or nonprofit entities;
- salary, royalties or other payments that, when aggregated for the investigator and a spouse/partner and dependent children, did not exceed $5,000 in the twelve months preceding the disclosure and are not expected to exceed $5,000 over the next 12 months.
- Or an equity interest that, when aggregated for the investigator, spouse/partner, and dependent children, does not exceed $5,000 and does not represent more than a five percent ownership interest in any entity is also not considered a SFI.
Significant Financial Interest Disclosures
“Investigators” submitting a grant or contract proposal to the agencies named below must complete the Financial COI Disclosure Dynamic Form before proposal submission annually, and within 30 days of discovering or acquiring a new SFI.
- National Science Foundation (NSF)
- A Public Health Service (PHS) Agency
- Agency for Healthcare Research and Quality (AHRQ)
- Agency for Toxic Substances and Disease Registry (ATSDR)
- Centers for Disease Control and Prevention (CDC)
- Food and Drug Administration (FDA)
- Health Resources and Services Administration (HRSA)
- Indian Health Service (IHS)
- National Institutes of Health (NIH)
- Office of the Assistant Secretary for Health (OASH)
- Office of the Assistant Secretary for Planning and Evaluation
- Office of the Assistant Secretary for Preparedness and Response (ASPR)
- Substance Abuse and Mental Health Services Administration (SAMHSA)
- Administration for Community Living (ACL)
- Administration for Children & Families (ACF)
- Office of National Coordinator for Health Information Technology (ONC)
- Organizations following PHS regulations:
- Alliance for Lupus Research
- Alpha-1 Foundation
- American Asthma Foundations
- American Cancer Society
- American Heart Association
- American Lung Association
- American Lung Association of Michigan
- Arthritis Foundation
- Department of Energy
- JDRF - Juvenile Diabetes Research Foundation
- Lupus Foundation of America
- Patient-Centered Outcomes Research Institute (PCORI)
- Susan G. Komen Foundation
- Small Business Innovation Program or Small Business Technology Transfer Program (conducting research or educational activities pursuant to such a federal grant or contract at the University as an investigator).
Required Conflicts of Interest Training
To comply with federal requirements, all principal investigators and key personnel who apply for, or work on a project funded by a PHS agency or an agency that has adopted the PHS requirements (see list above), must complete the online CITI Training Course titled, “Conflicts of Interest.”
When should this training be done?
- before engaging in research
- at least every four years
- immediately upon institutional FCOI change in a manner that affects investigator requirements
- when an investigator is new to the institution
- when an investigator is found noncompliant with the institution’s FCOI policy or management plan.
Registering for CITI training
- If you have not registered with CITI before, use this guide COI CITI instructions to register and sign up to help you register and enroll in the Conflicts of Interest course.
- If you have registered with CITI, use this guide COI CITI instructions to sign up when already registered to enroll in the Conflicts of Interest Course.