Overview
Per PHS Regulations, all investigators on a PHS (including NIH) funded research project who are listed as "key personnel" on the Financial Conflict of Interest (FCOI) Key Investigator List must complete a financial disclosure:
(i) Annually;
(ii) Within 30 days of acquiring a new, significant financial interest; or
(iii) At the time their proposal is submitted to the PHS entity for funding
Additionally, a number of federal agencies have adopted federal FCOI regulations. If your research project is sponsored by an entity on this Adoptive Entities List and you are listed as "key personnel," you will be required to complete a financial disclosure.
Forms
Disclosures are completed in Huron. Other forms that may need to be completed, depending on project details:
- FCOI Training for Subrecipients provides training for PHS subrecipient investigators when their institution does not have a compliant PHS policy.
- FCOI Subrecipient Form A that must be completed by all PHS subrecipients that are not affiliated with compliant institutions listed on the FDP FCOI Clearinghouse
- FCOI Subrecipient Form B that must be completed by PHS subrecipient investigators when their institution does not have a compliant PHS policy.
UCSF Applicable Policy
UCSF Policy 700-11: Disclosure of Financial Interests & Management of Conflicts of Interests, Public Health Service (PHS) Research Awards