Financial Conflict of Interest (FCOI)

The Financial Conflict of Interest Policy, Grants Information Memorandum (GIM) 10, establishes guidelines for disclosure of Significant Financial Interests and management of resulting Financial Conflicts of Interests in research, sponsored programs, and technology transfer activities at the University. The information accessible through this page provides details of relevant policies, procedures, and systems. 

What is a Financial Conflict of Interest? 

A Financial Conflict of Interest in research is present when a Significant Financial Interest affects, or could appear to affect, the professional judgment of a researcher when designing, conducting, or reporting research. 

Who needs to disclose? 

• Institutional Review (IR) of all SFI is required for Investigators^† participating in any U.S. Public Health Service (PHS) and U.S. Department of Energy (DoE) sponsored activities. 
• Sponsors allowing Investigators^† to Determine (ID) when SFI is related to the Investigator’s research include the National Science Foundation (NSF) and National Aeronautics and Space Administration (NASA). Investigators^† participating in research with these sponsors must disclose those Significant Financial Interests they deem to be related to their research. 

^† Investigator status is determined by the Principal Investigator, FAQ.

What is considered an SFI?

An SFI exists when any of the following are received by an Investigator or their Immediate Family Member: 

• Combined compensation^* from, and equity in, in a publicly traded company exceeding $5,000 
• Compensation^* exceeding $5,000 from, or any equity in, a privately held company  
• Compensation^* exceeding $5,000 from Intellectual Property not managed by the University 

^* Sponsored or reimbursed travel cost is a form of compensation when associated with a performed service. 

When do I disclose?

New or increased SFI need to be disclosed: 

• Within thirty (30) days of acquisition 
• Within thirty (30) days of starting a new, or joining an ongoing, research project 
• At least annually by IR Investigators

Why do I need to disclose?

State and Federal regulations require the University of Washington to have policies in place to promote objectivity in research, as well as to address State laws prohibiting state employees from having an interest that is in conflict with their official duties (RCW 42.52). 

How do I disclose?

Using the Financial Interest Disclosure System (FIDS) –  Overview and Navigation.

Collaborations and Reporting PHS FCOI

For collaborating institutions reporting FCOI (subrecipients of UW awards) or requesting updates regarding FCOIs identified in PHS-Sponsored Research at the University of Washington (prime awardees issuing subawards to UW) please contact us at fcoirep@uw.edu. 

Subrecipient Compliance 

All subrecipients proposed must have their own FCOI compliant policy in place and make an assurance in the subaward to this regard. Reminders to the PI and eGC1 contacts regarding this requirement will be sent by OSP at JIT and award stage for projects or programs sponsored by an organization requiring Institutional Review of Investigator SFI.  

For agencies or subrecipients that do not yet have their own policy, the National Institutes of Health (NIH) offer a Checklist for Policy Development. 

Scenarios

I’m an Investigator participating in research where the sponsor requires Institutional Review and I received $5,000 in compensation for serving on the Scientific Advisory Board of a local biotechnology company within the past several months. I anticipate receiving an additional $2,000 for these services in the next few months of this total 12-month period—am I required to disclose this compensation? 

Yes, compensation exceeding $5,000 received, or anticipated to be received, within a twelve (12) month period requires disclosure under GIM 10. (If only the original $5,000 in compensation were received, and no additional compensation was anticipated, then threshold for SFI would not be met and no disclosure would be required. Likewise, if greater than 12 months elapsed between receipt of the original $5,000 and the additional $2,000 and no other compensation was received or anticipated, no disclosure would be required).

I’m working with an Investigator Determined sponsor on research and I received $6,000 in compensation for serving on an Engineering Advisory Board for an Industrial Engineering firm—am I required to disclose this compensation? 

If you advised on products or services you are evaluating in the course of your University research, or you determine the work you are doing on the Advisory Board is related to any of your University research, you must disclose this compensation and may be issued a Conflict Management Plan to mitigate any perceived or actual concerns that may arise under Washington State Ethics laws. 

I am working with CoMotion to patent technology that I developed in my University laboratory. Do I need to disclose this as an Intellectual Property interest? What if I’m on the Board of Directors for a Company that wishes to license my technology? 

No. Intellectual Property, and any associated royalties or payments that are managed by the University are considered to fall within your University responsibilities and compensation. However, disclosures of Significant Financial Interests in private companies should be submitted by IR-Investigators regardless of the entities’ interest in University technology. All Innovators with SFI in an entity licensing technology for which they are a contributor will be issued a Conflict Management Plan. CoMotion and the Office of Research work together closely at the time of negotiation of the IP agreement to support compliance with applicable policies. 

I am receiving money from Industry, both for my University salary and for expenses to conduct research related to one of their products or services, should I disclose this as SFI? 

No. Any sponsored-research managed by the University, that is—it was routed through an eGC1 and negotiated by the Office of Sponsored Programs—is considered to fall within the scope of your University responsibilities and compensation. If the entity sponsoring University research is also paying you directly for other services, that compensation may require disclosure as outlined by GIM 10. 

Additional Considerations

• Sponsors allowing for Investigator Determined disclosures of SFI require reporting only those Significant Financial Interests the Investigator deems to be related to their research. Because the Investigator has made a determination of relatedness, many SFIs disclosed for these sponsored programs will result in a Conflict Management Plan being issued. 
• Technology Transfer (Intellectual Property) transactions in which a University Innovator has a Significant Financial Interest in the entity licensing the University technology require Conflict Management. 
• Financial Conflicts of Interest identified in PHS- and Department of Energy Sponsored Research must be made available to the public, and so are posted to a University of Washington webpage by the Office of Research. PHS FCOI are also reported annually to the sponsoring agency by the Office of Research via eRA Commons.

FAQs

I submitted and received approval for outside work via the Request for Approval of Outside Professional Work for Compensation (Form 1460)  process, do I also need to report the compensation as a Significant Financial Interest in FIDS? 

Yes, if the compensation meets thresholds defined in GIM 10 it may require disclosure in FIDS. 

Who

Who is an Investigator?

An “Investigator” includes the Principal Investigator (PI) and any other University person, regardless of title or position, that is responsible for the design, conduct, or reporting of research. Additional guidance. 

Do I need to submit disclosures of my Significant Financial Interests?

All Investigators should be submitting disclosures of Significant Financial Interests. For personnel receiving sponsored funding from agencies allowing for Investigator Determined reporting of SFI, these disclosures need only occur when the Investigator determines the SFI is related to the research. For agencies requiring Institutional Review of SFI all Investigators, that is, anyone contributing to the design, conduct, or reporting of the research—are required to disclose SFI or affirm they have no SFI. This includes faculty, postdoctoral scholars, graduate students, undergraduate students, and staff. 

Can my Department Administrator or Assistant submit my disclosures for me?

No. Investigators are required to use their own University NetID to log in to FIDS and complete their disclosures. 

What

Do I need to access FIDS?

All you need is your University NetID and your password. 

Detail do I need to include about services I’ve provided which resulted in this external compensation?

Including a concise description of outside work activities, and/or a description of the company’s business or the business for which services were provided, will enable the quickest review of SFI for FCOI and will reduce the likelihood that the Office of Research will need to contact you to collect more detail about the disclosed SFI. 

When

Do I have to disclose SFI?

ID Investigators must disclose related SFI at the time of eGC1 submission to OSP. IR Investigators are required to disclose prior to application, within thirty (30) days of joining a research project, and at least annually. 

Are my disclosures reviewed?

In most cases, SFI are not reviewed until and unless an award is made. Exceptions include: No Cost Extensions, Advance Budget Requests, Technology Transfer Agreements, and unsponsored research that requires IRB approval, Gift Funded Research. 

How

Do I certify to the sponsor that I’ve completed the required training or submitted a disclosure?

The Office of Sponsored Programs handles all certifications, both for individuals and the institution. If your sponsor is requiring additional certifications, such as assurance of no institutional conflict, contact the Office of Research for assistance.

Do I request SFI review for an IRB activity that does not have a corresponding eGC1? 

Contact the Office of Research for assistance.