Guide to Services

Financial Conflicts of Interest for PHS-Sponsored Projects

HJF has a policy comply with PHS regulations governing financial conflicts of interest (FCOI) disclosure and reporting for investigators that apply for and receive research funding from the PHS  The policy applies to any proposal submission and any funding received from PHS beginning 8/24/12.

PHS regulations and HJF’s policy requires all Investigators (excluding federal personnel) receiving funds from PHS to complete special FCOI training prior to submitting a proposal or engaging in research related to any PHS funded grant, cooperative agreement or contract that receives funding after the effective date of the policy (8/24/12).  This includes direct PHS funding as well as PHS funding passed through another non-federal institution via subaward or subcontract.  The training certification is valid for four years.

“Investigator” is defined as the project director Principal Investigator and any other person, regardless of title or position, who is responsible for the design, conduct, or reporting of research funded by the PHS, or proposed for such funding, which may include, for example, collaborators or consultants.  Note:  In the context of this FCOI policy, for disclosure purposes the term “Investigator’ includes the Investigator’s spouse and dependent children.

To assist investigators with compliance, HJF has added an online module related to PHS FCOI rules that can be used to certify training compliance. The online training course takes about 40 minutes to complete. By registering for the training under HJF, we will be able to verify completion of the training for audit and certification purposes. HJF also recommends investigators print the certificate verifying completion for their records.

In addition to the training, the scope for disclosure has been expanded to include all investigators (as defined above) and their spouses and dependent children. The threshold for disclosure has been lowered as well. HJF’s policy and related training explain the requirements. HJF recommends anyone working on projects funded by the PHS or contemplating proposal submission to NIH or a related PHS agency become familiar with the policy immediately.

If you have any questions please contact HJF Office of Sponsored Programs at 240-694-4040.