Financial Conflict of Interest in Research
The FAU Financial Conflict of Interest (FCOI) Committee exists to ensure that all potential financial conflicts of interest related to FAU research are managed appropriately. The FCOI Committee is a faculty led committee that reviews disclosures made by researchers, identifies conflicts of interest, and helps researchers develop plans to manage those conflicts.
More details can be found in the Financial Conflict of Interest (FCOI) Policy.
All FCOI Disclosures should be made through Novelution.
FCOI Disclosure is a two-step process: Significant Financial Interest Disclosure and Project Specific Disclosure.
Significant Financial Interest Disclosure (SFI):
This disclosure should be completed by any key personnel for a sponsored research project who have any significant outside financial interests. You can edit your SFI in Novelution by selecting 'My SFI Disclosure' from the FCOI drop down at the top. Your SFI should be updated whenever your interests change.
Project Specific Disclosure (PSD):
Researchers who have submitted an SFI will be asked to complete a PSD for each sponsored project. The PSD asks the researcher to relate the goals and activities of their disclosed outside interests to the goals and activities of the sponsored research project in question.
Training:
All key personnel must complete the CITI FCOI training.
- Log in to citiprogram.org.
- Click 'My Courses' and 'View Courses' for Florida Atlantic University.
- At the bottom of the page, select 'Add a Course.'
- Select option 4, 'Conflict of Interest (COI)' and click 'Next.'
- The Conflict of Interest Stage 1 course is now added to your account.
- Select 'Start Now' to begin the course.
- If you have already completed Conflict of Interest Stage 1, and the expiration date is within the next 90-days, the same steps will enroll you in the Stage 2 Refresher course.
If you do not already have a CITI account, you first need to create an account and select Florida Atlantic University as your affiliation.
FCOI Committee Review:
All Disclosures are reviewed by the FCOI Committee to identify potential financial conflicts of interest. To ensure a quick review, please include enough information in your disclosures to allow the Committee to make an independent determination regarding the potential for conflict of interest.
SBIR and STTR funded projects may have different review requirements.
FCOI Meeting Dates
Meetings are conducted on the third Wednesday of each month unless otherwise noted. Dates are subject to change.May 15, 2024
F.A.Q.
What is a Financial Conflict of Interest?
A financial conflict of interest exists when an investigators's significant financial interest could affect the design, conduct, or reporting of research. Any potential financial conflict of interest must be managed in order to ensure the integrity of the research, the safety of any research participants, and the proper development of any intellectual property.
What constitutes a Significant Financial Interest?
A Significant Financial Interest includes any entity where the researcher's equity and remuneration combined exceed $5000, any non-publicly traded entity in which the researcher has any equity, or any intellectual property, patents, or copywrites. Disclosures must also be made for the researcher's spouse and dependent children. The SFI can be updated in Novelution at any time. More information can be found in the Financial Conflict of Interest (FCOI) Policy.
When do I need to update my SFI Disclosure?
SFI disclosures should be updated:
- Annually
- Prior to submitting proposals for internal or external funding
- Within 30 days of acquiring a new SFI
- Within 30 days of joining a research project already in progress
- Within 30 days of any reimbursed or sponsored travel
What interests do NOT require an SFI Disclosure?
Significant Financial Interest does NOT include
- remuneration from FAU
- remuneration paid to a researcher’s family by any entity that would not reasonably appear to be related to research activities
- remuneration from authorship of academic or scholarly works, regardless of the source
- remuneration from seminars, lectures, or teaching engagements sponsored by governmental agencies or institutes of higher education within the U.S.
- investment by a mutual fund, pension fund or other investment fund
When do I need to submit a PSD?
Novelution will prompt researchers with sponsored research projects to complete a PSD for each project. This disclosure must be submitted and reviewed before funds can be released.
What information should be included in the PSD?
The PSD should serve as a record of all information required by the FCOI Committee to make an independent determination as to the potential for a financial conflict of interest. Please address the following questions for each outside interest:
- What is the goal of your outside interest?
- What is your role in the outside interest?
- What is the goal of your sponsored research project?
- What is your role in the sponsored research project?
- Describe any way that your outside interest is directly related to your sponsored research project.
- Describe how the goals of your outside interest and the goals of your sponsored research project do or do not indirectly overlap or conflict.
- Describe any steps you have taken to ensure the objectivity and integrity of your research given your outside interest.
Federal Regulations
- NIH Grants & Funding FCOI Requirements
- Department of Health and Human Services Final Rule 42 CFR Part 50 and Part 90
- eCFR 42 CFR Part 50 Subpart F
Questions can be directed to:
C. Elisa Gaucher, Assistant Vice President for Research Integrity, egaucher@fau.edu,
or Miriam Campo, Assistant Vice President for Sponsored Programs, campom@fau.edu