Financial Conflict of Interest (FCOI)

In the Setup stage, Significant Financial Interest (SFI) disclosures submitted by Investigators at time of proposal are reviewed by the Office of Research for potential conflicts in accordance with the University’s Financial Conflict of Interest Policy, GIM 10. Conflict Management Plans are issued to Investigators with a conflict that can be reduced, eliminated, or managed. These plans are issued, and in some cases will require written acceptance, before release of sponsored research funds for expenditure. The Principal Investigator should be aware of any restrictions or conditions imposed on collaborating researchers which may limit their ability to perform research as described in application or award documents.

Roles

• Principal Investigators are responsible for identifying Investigators (any University person regardless of title or position, who will contribute to the design, conduct, or reporting of research) and ensuring they have ‘Investigator’ status in the corresponding eGC1 to ensure proper disclosure and review of SFI.
• Investigators are responsible for completing FCOI training once every 4-years and timely reporting of their SFI in the Financial Interest Disclosure System (FIDS).
• The Office of Research is responsible for Institutional compliance with Federal Regulation for Promoting Objectivity in Research and State Laws governing Ethics in Public Service to the extent described in GIM 10.

Plan/Act

• Confirm all UW employees, regardless of title or position, who will contribute to the research design, conduct, or reporting have ‘Investigator’ status in the eGC1.
• Review your currently disclosed SFI, update end date of an activity, change the compensation amount, or delete as appropriate.
• For questions regarding disclosure requirements or how SFI are reviewed contact the Office of Research.
• If you have multiple Investigators on your project, you may want to review their FCOI training status as completion is a requirement prior to expenditure of funds, you may view this information in the eGC1 or using MyResearch.
• Research collaborations with Institutions that do not maintain a policy consistent with PHS requirements may require additional coordination time, if you anticipate issuing a subaward to an emerging research institution or other small organization; the Investigator(s) at that site may need to rely on the UW’s policy, which requires additional administrative coordination. Contact OSP or the Office of Research with questions.
• Conflict Management Plans may impose restrictions or conditions on research that require coordination. In some cases it may be required to identify and gain approval of a colleague, or other individual, to be appointed in an administrative oversight role. If you think you might have an FCOI, work with your department and the Office of Research early to prevent delays in starting your project.
• If your research involves Human Subjects and a participating Investigator has been issued a Conflict Management Plan, the Principal Investigator is responsible for ensuring the IRB of record has been notified of the conflict and proposed mitigation. If you are a Co-Investigator or are collaborating on research involving human subjects, you are responsible for ensuring the Principal Investigator receives a copy of the Plan for reporting to the IRB.