03/01/2026
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please see below update ;
UTH Financial Conflict of Interest (FCOI) Policy
Version 1.0
Effective Date: September 4, 2025
Updated: December 23, 2025
Table of Contents
1. Introduction 2
2. Scope 2
3. Definitions 2
4. Significant Financial Interest (SFI) Disclosure Requirements 5
5. Review of SFI Disclosures 5
6. Relatedness of SFI to PHS/NIH-Funded Research and FCOI 6
7. Management of SFI that Pose a FCOI 6
8. Monitoring Investigator Compliance 6
9. Public Access to the FCOI Policy and Related Information 7
10. Reporting Financial Conflicts of Interest 8
11. Training Requirements 9
12. Noncompliance With FCOI Policy And Corrective Actions 10
13. Clinical Research Requirements 10
14. Subrecipient Requirements 10
15. Maintenance of Records 11
16. Enforcement Actions for Investigator Noncompliance 11
17. Useful FCOI AND NIH Resources 12
18. Point Of Contact 12
1. Introduction
The purpose of this policy is to ensure that research funded by the National Institutes of Health (NIH) is designed, conducted, and reported objectively and without bias resulting from Investigator financial conflicts of interest (FCOI). The United States Department of Health and Human Services (HHS) developed the 1995 and revised 2011 regulations at 42 CFR Part 50 Subpart F, “Promoting Objectivity in Research” and 45 CFR Part 94, “Responsible Prospective Contractors” to promote objectivity in Public Health Service (PHS) funded research for grants, cooperative agreement and research contracts, respectively. The regulations apply to all National Institutes of Health (NIH) applications and funded grants, cooperative agreements, and research contracts, excluding the Phase 1 Small Business Innovation Research (SBIR) or Small Business Technology Transfer (STTR) applications and/or awards. The implementation of the regulation, through the issuance of this policy, establishes standards that provide a reasonable expectation that the design, conduct and reporting of PHS/NIH-funded will be protected from bias resulting from an Investigator’s financial conflict of interest (FCOI). This policy also serves to protect the safety of animals and human research participants, the reputation of the recipient institution and of the “Investigator” who participates in PHS/NIH-funded research. These requirements also work together to preserve the public’s trust that the research supported by the PHS/NIH is conducted without bias and with the highest scientific and ethical standards.
Applicability-This policy implements the regulatory requirements provided in 42 CFR Part 50 Subpart F for grants and cooperative agreements issued by the NIH. The policy also applies to individuals who meet the regulatory definition of “Investigator” (as defined below) who are planning to participate in, or who participate in NIH-funded research. The regulations do not apply to Phase I SBIR or STTR applications or awards. This policy implements the regulatory requirements for PHS/NIH grants and cooperative agreements.
University Teaching Hospitals (“UTH”, “The Institution”) adopts this policy for all Investigators (as defined below) engaged in PHS/NIH-funded research. It establishes processes to identify, disclose, and manage Investigator financial conflicts of interest to protect research integrity, ensure the safety of human and animal subjects, and maintain public trust in PHS/NIH-supported research.
2. Scope
This policy applies to all Investigators who are responsible for the design, conduct, or reporting of NIH-funded research at UTH. It also applies to “Investigators” who participate as employees, subcontractors, or collaborators on NIH-funded projects.
3. Definitions
For the purpose of these policies and procedures, the following definitions apply:
Federal: Federal refers to United States federal institutions.
Financial conflict of interest (FCOI): A significant financial interest (SFI) that is related to the PHS/NIH- funded research (i.e., the SFI could be affected by the research or the SFI is in an entity whose financial interest could be affected by the research) and could directly and significantly affect the design, conduct, or reporting of PHS-funded research.
Financial Interest: Anything of monetary value, whether or not its value is readily ascertainable.
Foreign: All countries except the United States. Zambia, in this context, is foreign.
Institutional Responsibilities: The professional activities an Investigator performs on behalf of UTH including research, product development and testing, publication and communication of research, consulting, operations management, administration, fundraising, data and safety monitoring boards, and institutional committee memberships or panels.
FCOI Designated Official (FCOI DO): The individual appointed by UTH to solicit and review disclosures of significant financial interests, determine FCOIs in accordance with 42 CFR 50.604(f) and this policy, and develop management plans for identified FCOI.
Institution: Any public or private organization, domestic or foreign (excluding a federal agency) that is applying for or receives, PHS/NIH research funding.
Investigator: The Project Director (PD), Principal Investigator (PI), or any individual, regardless of title or position, who is responsible for the design, conduct, or reporting of research funded or proposed for funding. This may include collaborators or consultants. UTH determines who is responsible for the design, conduct, or reporting of PHS-funded research based on an individual’s role and level of independence, not their title.
Manage: means taking action to address a financial conflict of interest, which can include reducing or eliminating the financial conflict of interest, to ensure, to the extent possible, that the design, conduct, and reporting of research will be free from bias.
Research: A systematic investigation, study, or experiment designed to develop or contribute to general knowledge relating broadly to public health, including biomedical research. This term includes both basic and applied research (e.g., published articles, books, or book chapters) and product development (e.g., diagnostic devices or analytical instruments).
PHS-Funded Research: Any activity supported by a US Public Health Service (PHS) Awarding Component through a grant, cooperative agreement, or contract, whether funded under the PHS Act or other statutory authority.
PHS: The Public Health Service of the U.S. Department of Health and Human Services, and any components of the PHS to which the authority involved may be delegated, including the National Institutes of Health (NIH).
NIH: The biomedical research agency within the Public Health Service (PHS) that funds and conducts research to improve health and advance scientific knowledge.
Senior/Key Personnel: The PD/PI and any other individual identified as senior/key personnel by the Institution in a grant application, progress report, or other submission to PHS/NIH. For this policy, the term applies specifically to the public accessibility requirement, which mandates disclosure only of financial conflicts of interest held by these senior/key personnel, as described in Section 9.
Significant Financial Interest (SFI):
A US or foreign financial interest of the Investigator, the Investigator’s spouse, and dependent children that reasonably appears to relate to the Investigator’s institutional responsibilities on behalf of UTH, and that consists of one or more of the following:
• Publicly traded entity: An SFI exists if the total of remuneration received from the entity in the previous 12 months and the value of any equity interest in the entity on the disclosure date exceeds $5,000. Remuneration includes salary and payments for services (e.g., consulting fees, honoraria, paid authorship). Equity interest includes stock, stock options, or other ownership interests measured by public prices or other reasonable market value.
• Non-publicly traded entity: An SFI exists if the aggregated value of remuneration received from the entity in the 12 months preceding the disclosure exceeds $5,000, or if the Investigator (or their spouse or dependent children) holds any equity interest in the entity (e.g., stock, stock options, or other ownership interest).
• Intellectual property: An SFI exists if income related to intellectual property rights or interests (e.g., patents, copyrights) exceeds $5,000 during the 12 months preceding the disclosure.
Investigators must disclose any reimbursed or sponsored travel related to their institutional responsibilities with a value exceeding $5,000. Such travel includes trips paid on behalf of the Investigator rather than reimbursed directly, where the exact cost may not be known. The disclosure must cover the previous 12 months and include, at minimum, the purpose, sponsor or organizer, destination, and duration of each trip.
The disclosure requirement does not apply to travel that is reimbursed or sponsored by the following:
• a federal, state, or local government agency located in the United States,
• a United States Institution of higher education,
• an academic teaching hospital,
• a medical center, or
• a research institute affiliated with a United States Institution of Higher Education
The term “significant financial interest” does not include, and therefore investigators are not required to disclose, the following types of financial interests:
• Salary, royalties, or other remuneration paid by UTH to the Investigator if the Investigator is currently employed or otherwise appointed by UTH, including intellectual property rights assigned to UTH and any agreements to share royalties related to those rights.
• Income from investment vehicles such as mutual funds and retirement accounts, provided the Investigator does not directly control the investment decisions for those vehicles.
• Income from seminars, lectures, or teaching engagements sponsored by a U.S. federal, state, or local government agency, a U.S. institution of higher education, an academic teaching hospital, a medical center, or a research institute affiliated with a U.S. institution of higher education.
• Income from service on advisory committees or review panels for a U.S. federal, state, or local government agency, a U.S. institution of higher education, an academic teaching hospital, a medical center, or a research institute Affiliated with a U.S. institution of higher education.
Foreign (i.e. non-US) Financial Interests: Investigators must disclose all financial interests originating outside the United States, including income from seminars, lectures, teaching engagements, service on advisory committees or review panels, and reimbursed or sponsored travel, received from any foreign entity. This includes foreign institutions of higher education and foreign governments (including local or provincial governments). Disclosure is required when the aggregated amount of such income exceeds $5,000.
4. Significant Financial Interest (SFI) Disclosure Requirements
Investigators are required to disclose Significant Financial Interests (SFIs) at the following times:
At the time of the application: The PI and all other individuals who meet the definition of “Investigator” must disclose their SFIs to the DO(s). Any new Investigator who joins the project after the NIH application has been submitted or during the course of the research must also disclose their SFI(s) to the FCOI DO(s) promptly and before participating in the project, using the SFI Disclosure Form.
Annual Disclosure: Each Investigator participating in research under an NIH award must submit an updated SFI disclosure at least annually (on or before July 1) during the award period. The annual disclosure must include: (1) any new information that was not previously disclosed to UTH under this policy, including SFIs associated with NIH-funded projects transferred from another institution; and
(2) updated details for any previously disclosed SFI, such as change in the value of an equity interest
New SFIs during the award: Each Investigator participating in PHS/NIH-funded research must submit an updated SFI disclosure within 30 days of discovering or acquiring a new SFI (e.g., through purchase, marriage, or inheritance). Updated disclosure of reimbursed or sponsored travel must also be submitted within 30 days of each occurrence.
5. Review of SFI Disclosures
The Senior Medical Superintendent (SMS) of UTH or their designated appointee serves as the FCOI Designated Official (DO) responsible for reviewing all SFI disclosures. Each SFI will be evaluated in relation to every PHS/NIH research application or award on which the Investigator is responsible for the design, conduct, or reporting of research, to determine whether the SFI is related to the funded research and, if so, whether it constitutes a Financial Conflict of Interest (FCOI).
The SFI disclosures will be reviewed as described below:
• Prior to the issuance of a new award (i.e. before or during the Just-in-time submission stage): The FCOI DO will review the Investigator’s SFI to determine if the SFI is related to the research and constitutes an FCOI. If an FCOI is identified, the institution will develop a management plan and submit an FCOI report to the NIH via the eRA Commons FCOI Module prior to the expenditures of funds under the newly issued award.
• Annual SFI disclosure: As part of the annual disclosure process, Investigators must provide updated information on any previously disclosed SFIs (e.g., revised value of an equity interest). The FCOI DO will review these updates to determine whether changes to an existing management plan are needed. Any modifications will be reflected in the next Annual FCOI report submitted to NIH, if applicable. Annual SFI disclosures will also solicit the disclosure of any new discovered or acquired SFIs that were not previously reported.
• During award period: If a new Investigator joins a project or an existing Investigator acquires or discovers a new SFI during the project, the FCOI DO will, within 60 days: (1) review the disclosure; (2) determine whether the SFI is related to the PHS/NIH-funded research; (3) determine whether an FCOI exists; and, if so, (4) implement, on at least an interim basis, a management plan. An FCOI report will be submitted to NIH within 60 days of identifying the FCOI.
6. Relatedness of SFI to PHS/NIH-Funded Research and FCOI
The FCOI DO is responsible for assessing the relatedness of SFIs to NIH-funded research and determining when they constitute a FCOI.
Relatedness Test: The FCOI DO determines whether an Investigator’s SFI is related to research under an NIH award. An SFI is considered “related” when the FCOI DO reasonably determines that:
• The SFI could be affected by the PHS/NIH-funded research, or
• The SFI is in an entity whose financial interests could be affected by the PHS/NIH-funded research.
The FCOI DO may consult with the Investigator when assessing the SFI relatedness.
Designated Official FCOI Determination: An FCOI exists when the FCOI DO reasonably determines that the SFI could directly and significantly affect the design, conduct, or reporting of the PHS/NIH-funded research (“significantly” meaning that the financial interest would have a material effect on the research).
7. Management of SFI that Pose a FCOI
When an FCOI is identified, the FCOI DO will determine and implement management strategies to ensure the research is conducted objectively. Examples of management conditions include:
1. Public disclosure of the FCOI (e.g., in publications or presentations, to study personnel, to all approving IRBs, or Data Safety Monitoring Board). While public posting of FCOIs is required only for senior/key personnel, the FCOI DO may require disclosure of any Investigator’s FCOI as a condition of a management plan.
2. For human subjects’ research, disclosure of the FCOI to participants in the informed consent document
3. Appointment of an independent monitor to protect against bias in the design, conduct, and reporting of the research
4. Modification of the research plan
5. Change of personnel roles or removal from portions of the research
6. Reduction or elimination of the financial interest (e.g., divesting equity)
7. Severance of relationships creating the conflict
The FCOI DO will communicate the determination and the management plan in writing to the Investigator, the PI/PD, and the appropriate supervisor.
No expenditures on an NIH award may occur until the Investigator has met all disclosure requirements and agreed in writing to comply with the management plan. The FCOI DO will submit an FCOI report to NIH via the eRA Commons FCOI Module.
8. Monitoring Investigator Compliance
UTH will monitor Investigator compliance with the management plan for the duration of the NIH award or until the FCOI no longer exists. Monitoring includes verifying that required public disclosures of FCOIs are made in publications, presentations, and other communications. Investigators must also disclose the FCOI in writing to study personnel and provide a copy of this disclosure to the FCOI DO for record keeping.
9. Public Accessibility of FCOI Policy and FCOIs Held by Senior/Key Personnel
FCOI Policy: A copy of this FCOI policy is posted on the institutions public website per the NIH requirements in the NIH Grants Policy Statement Section 4.1.1 Financial Conflict of Interest at https://grants.nih.gov/grants/policy/nihgps/HTML5/section_4/4.1.10_financial_conflict_of_interest.htm
Identified FCOIs held by Senior/key Personnel: Before any funds are spent under an NIH award, UTH will ensure public accessibility, either by posting on a publicly accessible website or by providing a written response, within five business days to requests for information about any SFI that meets all three of the following criteria:
• The SFI was disclosed, is still held by Senior/Key Personnel (the PD/PI and any other individual identified by UTH as senior/key personnel in the application, progress report, or other NIH submission).
• UTH has determined that the SFI is related to the NIH-funded research.
• UTH has determined that the SFI constitutes an FCOI.
When applicable, UTH will make available at least the following information:
• Investigator’s name
• Investigator’s title and role with respect to the research project
• Name of the entity in which the SFI is held
• Nature of the SFI
• Approximate dollar value of the SFI in the following ranges: $0–$4,999; $5,000–$9,999;
$10,000–$19,999; amounts between $20,000 and $100,000 by increments of $20,000; amounts above $100,000 by increments of $50,000; or a statement that the value cannot be readily determined by public prices or reasonable fair market value measures
The written response will note that the information provided is current as of the date of the correspondence and is subject to updates on at least an annual basis and within 60 days of the institution’s identification of a new FCOI, which should be requested subsequently by the requestor.
If UTH uses a publicly accessible website to meet this requirement, the information will be updated at least annually and within 60 days of:
• Receiving or identifying an additional SFI of Senior/Key Personnel related to the NIH-funded research that was not previously disclosed, or
• A new SFI being disclosed by Senior/Key Personnel joining the project and determined by the FCOI DO to be related and an FCOI.
Information on SFIs subject to public accessibility will remain available for at least three years from the most recent update.
10. Reporting Financial Conflicts of Interest
Prior to spending any funds under an NIH-funded award, UTH will submit an FCOI report to NIH, in accordance with NIH regulations, for any Investigator’s SFI determined to be an FCOI. UTH will also ensure that the Investigator has agreed to and begun implementing the associated management plan.
UTH will designate an institutional official to act as the FCOI Signing Official (FCOI SO) in the eRA Commons FCOI Module. The FCOI SO is authorized to submit FCOI reports to NIH. FCOI reports are submitted only when an award is active and an FCOI has been identified (i.e., no award means no FCOI report, and no FCOI means no FCOI report).
The NIH eRA Commons FCOI Module User Guide, available at the following location provides instructions for preparing and submitting FCOI reports.https://www.era.nih.gov/%EF%AC%81les/fcoi_user_guide.pdf
Initial (Original) FCOI Reports
• Prior to the expenditure of funds: If an FCOI is identified at the time a new NIH award is issued, the FCOI SO will submit an “Original” FCOI report (2011 FCOI) through the eRA Commons FCOI Module before any funds are spent. The report must include all information required under 42 CFR 50.605(b)(3) or as outlined in NIH FAQ H.5 https://grants.nih.gov/faqs #/ .
• Within 60 days during the award: If an FCOI is identified during the award period (e.g., a new SFI is disclosed or a new Investigator joins the project), the Institution must submit an Original FCOI report within 60 days of identifying the FCOI.
Annual FCOI Reports: For the duration of an award, including any extensions with or without funds, the Institution must submit an annual FCOI report to NIH. This report will indicate whether each previously reported FCOI is still being managed or no longer exists and describe any changes to the management plan, if applicable.
• The annual report must be submitted at the same time as the Research Performance Progress Report (RPPR) or multi-year progress report, and at the time of any grant extension, following NIH guidance (see NIH FAQ H.2: https://grants.nih.gov/faqs #/ Annual FCOI reports are not required at grant closeout.
Revision (or Mitigation) FCOI Reports: After completing a retrospective review, the Institution will submit a Revision report to NIH if new information about the FCOI is discovered, or a Mitigation report if the review finds that bias has occurred.
Types of FCOI Reports Summary Chart for NIH:
Required FCOI Reports to NIH via eRA Commons FCOI Module
REPORT CONTENT REQUIRED WHEN
New FCOI
Report (Initial submission) Grant number; PI; name of entity with FCOI; nature of FCOI; value of the financial interest (in required increments); description of how the financial interest relates to the research; key elements of the management plan. Prior to the expenditure of funds on a new award; within 60 days of identifying any new FCOI during the award period.
Annual FCOI Report Status of the FCOI (whether it is still being managed or no longer exists) and any changes to the management plan, if applicable. Submitted annually at the same time as the annual progress report, multi-year progress report, or at the time of a grant extension.
Revised FCOI Report If applicable, updates to a previously submitted FCOI report to describe actions that will be taken to manage the FCOI going forward or to revise the original report. Following a retrospective review when noncompliance with the regulation is identified, if applicable.
Mitigation Report Project number; project title; contact PI/PD; name of Investigator with FCOI; name of entity with FCOI; reason for review; detailed methodology, findings, and conclusions.
After a retrospective review when bias is found.
11. Training Requirements
Each Investigator will be informed of UTH’s FCOI Policy and trained on their responsibility to disclose foreign and domestic SFIs under this policy and the FCOI regulation at 42 CFR Part 50 Subpart F. Training must be completed before an Investigator engages in PHS/NIH-funded research, at least once every four years, and promptly (as described below) when any of the following occur:
• UTH revises this policy or related procedures in a way that affects Investigator requirements.
• An Investigator is new to UTH research under an NIH award (training must be completed before participating in the research).
• UTH determines that an Investigator has not complied with this policy or with a management plan issued under it (training must be completed within 30 days as directed by the FCOI DO).
To meet the NIH training requirement, UTH requires Investigators to complete the NIH FCOI tutorial from the following location, print and retain the completion certificate for audit purposes. https://grants.nih.gov/grants/policy/coi/tutorial2018/story_html5.html
UTH also requires Investigators to review the NIH Virtual Seminar presentation on FCOI compliance from the following location: https://www.youtube.com/watch?v=D292YZ6BX24
Addendum 3Dec2025
Investigators who have completed appropriate and comparable training within the manded time period outlined above through a formal affiliation with a US University may be exempted from the UTH training requirements but are still mandated to report.
12. Noncompliance with FCOI Policy and Corrective Actions
If UTH identifies an SFI that was not disclosed, reviewed, or managed in a timely manner, the FCOI DO will, within 60 days: review the SFI; determine whether it is related to NIH-funded research; determine whether it constitutes an FCOI; and, if so, implement an interim management plan describing actions that have been and will be taken to manage the FCOI going forward. UTH will also submit an FCOI report to NIH via the eRA Commons FCOI Module.
In cases of noncompliance, including:
• Failure by the Investigator to disclose an SFI that is later determined to constitute an FCOI
• Failure by the institution to review or manage an FCOI
• Failure by the Investigator to comply with an established management plan
UTH will, within 120 days of identifying noncompliance:
• Conduct a retrospective review of the Investigator’s activities and the NIH-funded research to determine whether the research, or any part of it, was biased in the design, conduct, or reporting.
• Document the retrospective review in accordance with 42 CFR 50.605(a)(3)(ii)(B) or NIH FAQ I.2 (https://grants.nih.gov/faqs #/ ).
If bias is found, UTH will promptly notify NIH and submit a mitigation report as required by 42 CFR 50.605(a)(3)(iii) or NIH FAQ I.3 (https://grants.nih.gov/faqs #/ ). The report will include:
• The impact of the bias on the research project, and
• The plan of action or corrective steps taken to eliminate or mitigate the effect of the bias.
UTH will thereafter submit FCOI reports annually to NIH as required by the regulations and the terms and conditions of the award. Depending on the circumstances, UTH may implement additional interim measures regarding the Investigator’s participation in the research until the retrospective review is complete. If no bias is found, no further action is required.
13. Clinical Research Requirements
If HHS determines that a PHS-funded clinical research project evaluating the safety or effectiveness of a drug, medical device, or treatment was designed, conducted, or reported by an Investigator with an unmanaged or unreported FCOI, UTH will require the Investigator to disclose the conflict in every public presentation of the research results and to request an addendum to previously published presentations.
14. Subrecipient Requirements
A subrecipient relationship exists when federal funds flow from or through UTH to another individual or entity that will carry out a substantive portion of a PHS-funded research project and is accountable to UTH for programmatic outcomes and compliance. Subrecipients (e.g. collaborators, consortium members, consultants, contractors, subcontractors, and sub-awardees) are subject to UTH’s terms and conditions. UTH will take reasonable steps to ensure that all subrecipient Investigators comply with the federal FCOI regulations at 42 CFR Part 50 Subpart F.
UTH will include in each written agreement with a subrecipient terms specifying whether UTH’s FCOI Policy or the subrecipient’s own FCOI policy will apply to subrecipient Investigators (see NIH Grants Policy Statement Section 15.2.1 on Written Agreements: https://grants.nih.gov/grants/policy/nihgps/html5/section_15/15.2_administrative_and_other_requirements.htm ).
• If the subrecipient’s FCOI policy applies:
The subrecipient institution must certify in the agreement that its policy complies with federal FCOI regulations. The agreement will specify the timeframe for the subrecipient to report identified FCOIs to UTH in time for UTH to meet NIH reporting deadlines (i.e., before funds are spent and within 60 days of the subrecipient identifying an FCOI). Typically, this means requiring subrecipients to report FCOIs to UTH within 50–55 days of identification. UTH’s FCOI DO will then submit the subrecipient FCOI report to NIH through the eRA Commons FCOI Module.
• If the subrecipient cannot certify compliance:
The agreement will specify that UTH’s FCOI Policy applies. In this case, subrecipient Investigators must disclose their SFIs to UTH. The written agreement will specify the time period(s) for the subrecipient to submit all Investigator SFI disclosures to the awardee institution. The SFI disclosure must include SFIs that are directly related to the subrecipient’s work for UTH. The agreement will allow sufficient time for UTH to review, manage, and report any resulting FCOIs. When an FCOI is identified, UTH will implement a management plan, monitor compliance by the subrecipient Investigator, and submit the required FCOI report to NIH via the eRA Commons FCOI Module.
15. Maintenance of Records
UTH will maintain records of all Investigator financial interest disclosures, UTH’s review and response to those disclosures (whether or not they resulted in a determination of an FCOI), and any actions taken under this policy or through retrospective review. These records will be retained for at least three years from the date of submission of the final expenditures report, or for longer periods as specified in 45 CFR 75.361 for specific situations. UTH will retain these records for each competitive segment as required by regulation.
16. Enforcement Actions for Investigator Noncompliance
Compliance with this policy is a condition of UTH employee participation in PHS-funded research for all applicable Investigators. Investigators who fail to comply may be subject to disciplinary action, which can include termination of employment or contract, formal warning letter or official notice of disciplinary action, restrictions on the use of research funds, and/or disqualification from further participation in any PHS/NIH-funded research, as deemed appropriate.
17. Useful FCOI AND NIH Resources
NIH e-mail address for FCOI-related inquiries
http://mail.nih.gov/
FCOI Regulation 42 CFR Part 50 Subpart F-Promoting Objectivity in Research
https://grants.nih.gov/policy-and-compliance/welcome-wagon
Financial Conflict of Interest
https://grants.nih.gov/policy-and-compliance/policy-topics/fcoi
FCOI Training
https://grants.nih.gov/policy-and-compliance/policy-topics/fcoi/fcoi-training
Information for Foreign Grants
https://grants.nih.gov/new-to-nih/information-for/foreign-grants
NIH “Welcome Wagon” Letter: Information for New Recipient Organizations
https://grants.nih.gov/policy-and-compliance/welcome-wagon
18. Point of Contact
If you have a question related to the FCOI Policy of UTH or would like to disclose a financial interest, contact us using the information below:
Contact:
The UTH FCOI Designated Official (FCOI DO) [email protected]
Annual FCOI Report Status of the FCOI (whether it is still being managed or no longer exists) and any changes to the management plan, if applicable. Submitted annually at the same time as the annual progress report, multi-year progress report, or at the time of a grant extension.
Revised FCOI Report If applicable, updates to a previously submitted FCOI report to describe actions that will be taken to manage the FCOI going forward or to revise the original report. Following a retrospective review when noncompliance with the regulation is identified, if applicable.
Mitigation Report Project number; project title; contact PI/PD; name of Investigator with FCOI; name of entity with FCOI; reason for review; detailed methodology, findings, and conclusions.
After a retrospective review when bias is found.
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