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The Graduate School, Rensselaer Polytechnic Institute

Division of Finance


Financial Conflict of Interest

In the sponsored research setting, a potential conflict exists when there is a possibility that an individual's outside financial interests could directly and significantly affect the design, conduct, or reporting of the research.

Managing Conflicts of Interest - presentation to Business Managers

The Public Health Service (PHS) has issued “Responsibility of Applicants for Promoting Objectivity in Research for Which PHS Funding is Sought” (42 CFR Part 50 Subpart F) which will go into effect on August 24, 2012. We refer to this as The National Institutes of Health (NIH) Financial Conflicts of Interest (FCOI). Universities receiving sponsored research funding from the NIH are required to comply with these new regulations. All NIH proposals and awards, increments and continuations here at Rensselaer with an award notice start date of August 24, 2012 or later will be subject to these new regulations.

This policy change at PHS is being instituted to promote objectivity in research by establishing standards that provide a reasonable expectation that the design, conduct and reporting of sponsored research, including grants, cooperative agreements and contracts, will be free from bias resulting from investigator financial conflicts of interest.

The new requirements include mandatory training for any investigator as defined by NIH; a decreased threshold for determining Significant Financial Interests (SFI) – a drop from $10,000 to $5,000; and the requirement that an institution receiving NIH funding have a mechanism in place to publicly disclose certain SFI events upon request. SFI’s must be disclosed at each of these five separate points in time:

• When responding to the Annual Conflict of Interest survey.

• When submitting a proposal.

• At the Just in Time (JIT) stage.

• Within 30 days of acquiring/discovering a SFI.

• Annually during the project period at the time of a noncompeting submissions.

Please view the full text of the NIH Notice and FAQ, along with Federal Register Notice for additional information.

NIH Notice NOT-OD-11-109

NIH FAQs to 2011 Revised Regulation

NIH - Grants and Funding - Financial Conflict of Interest

NIH FCOI Tutorial

Federal Register Notice