Financial Conflict of Interest

Financial Conflict of Interest

Midwestern University (MWU) and its research grant applicants must comply with financial conflict of interest (FCOI) requirements (42 CFR Part 50 Subpart F).  MWU's Office of Research & Sponsored Programs (ORSP) is committed to helping our applicants understand and meet the requirements that this regulation places on grant applicants and MWU.

What is the purpose of the FCOI regulation? 

The FCOI regulation was established to promote objectivity in research by establishing standards that provide a reasonable expectation that the design, conduct, and reporting of research funded under NIH grants or cooperative agreements will be free from bias resulting from Investigator FCOIs.

Which agencies do these changes apply to?

These changes are applicable to Investigators involved with Public Health Service (PHS) funded research, which includes the:

• National Institutes of Health (NIH)
• Health Resources and Services Administration (HRSA)
• Agency for Healthcare Research and Quality (AHRQ)
• Food and Drug Administration (FDA)
• Centers for Disease Control (CDC)
• Substance Abuse & Mental Health Services Administration (SAMHSA)
• Office of Public Health & Science (OPHS)
• Indian Health Service (HIS)

Who is covered by this regulation?

Investigators: This regulation applies to each Investigator who is planning to participate in or is participating in PHS-funded research. Investigator is broadly defined as "the Project Director or 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 NIH, or proposed for such funding, including persons who are subgrantees, contractors, consortium participants, collaborators, or consultants." The regulation is applicable to Investigators applying for all NIH award programs, excluding Small Business Innovative Research (SBIR) and Small Business Technology Transfer Research (STTR) Phase I applications.

Institutions: This regulation applies to MWU because we receive funds from a PHS entity.

So what do I need to do to be compliant?

1. Please review MWU’s FCOI Training slides. For a link to the training slides, please reach out to Krystina LaSorsa in IL (klasor@midwestern.edu) or Jack Guinan in AZ (jguina@midwestern.edu).
2. Please read MWU’s Conflict of Interest on Extramurally Funded Programs policy. This policy is located along with the training slides on our Canvas page. Upon completion of review of the training slides and the COI policy, follow the instructions to please complete the Certificate documenting that you have completed MWU’s FCOI Training. 
3. Finally, if not already completed, please fill out the Conflict of Interest Policy Disclosure Form C, obtain your supervisor's signature, and return a scanned copy to the ORSP (klasor@midwestern.edu for IL) or (jguina@midwestern.edu for AZ). Please contact the ORSP if you have any questions.

Portions of the above explanations were excerpted from the National Institutes of Health Office of Extramural Research's FCOI tutorial.