Federal regulation 42 CFR Part 50 Subpart F promotes objectivity in research by establishing standards that provide a reasonable expectation that the design, conduct, and reporting of research funded under Public Health Service (PHS) grants or cooperative agreements will be free from bias resulting from Investigator financial conflicts of interest. As an institution applying for and awarded PHS grants and cooperative agreements, Arkansas State University is required to collect a Financial Conflict of Interest (FCOI) statement on a yearly and ad-hoc basis from all investigators with PHS funding. In anticipation of FCOI disclosures requested beyond PHS funding, the Arkansas State University FCOI procedure includes all Federally-sponsored funding. Additionally, investigators must complete FCOI training when funded, and at least every four years thereafter.
Please complete the Financial Conflict of Interest Tutorial. Once the tutorial is complete, save the certificate and email it to the Director of Research Compliance at firstname.lastname@example.org. Please note: this tutorial only has to be completed every four years.
A Financial Conflict of Interest Disclosure Form must be completed at least once per year for investigators with Federally-sponsored funding. Refer to the FCOI Procedures for definitions and guidance completing the disclosure form. The FCOI Disclosure Form is required annually and on an ad-hoc basis. Refer to the FCOI Procedures for ad-hoc requirements. Return the FCOI Disclosure Form to the Director of Research Compliance at email@example.com.
Please direct questions about the Financial Conflict of Interest process to the Director of Research Compliance at firstname.lastname@example.org.
Q1: Why did I receive this email?
A1: Between July 1, 2013 to present you have been paid by (or provided match to) a Federal or Federal pass-through grant or contract and are required by law and Institution procedures to complete FCOI training and a disclosure form.
Q2: Where do I send my disclosure form and training certificate?
A2: Please email it to the Director of Research Compliance at email@example.com. or you may bring a hard copy to our office – Research & Technology Transfer – 6th floor of library.
Q3: Do I need to disclosure all my financial information?
A3: ASU and the Federal Government are not interested in your personal financial information (checking, savings, retirement, etc.) so please do not provide this type of information. ASU is required to disclose financial conflicts of interest that could directly and significantly affect the design, conduct, or reporting of the Federal or Federal pass-through grant or contract you are engaged in. Please review the training module and procedures document to determine what is and is not a financial interest and if you need to disclose it.
Q4: What is a Significant Financial Interest?
A4: Please refer to the training module and procedure document for more information and detail, but basically if you, your spouse or your dependent children receive a salary, stock option, ownership interest, intellectual property rights income, or travel funds as it directly relates to the design, conduct, or reporting of the research/project(s) you are engaged in you must disclose this information.
Q5: I’m not an Investigator so why do I need to complete this training and disclosure form?
A5: The term “Investigator” is defined as any person responsible for the design, conduct, or reporting of research… including sub grantees, contractors, consortium participants, collaborators or consultants. So, essentially everyone who is associated with a grant or contract meets this Federal definition.
Q6: I completed a Conflict of Interest form for Human Resources recently. Is this the same form?
A6: No, this is a completely different disclosure form that must be completed.
Q7: What will happen if I have a financial conflict of interest?
A7: Please review the procedures document for information on the process following a disclosure and how it will be managed.