COI

Financial Conflict of Interest (FCOI)

Policy and Procedures on Financial Conflict of Interest (FCOI) for Sponsored Programs

CSUDH Presidential Memo 2015-02 requires that each investigator of a sponsored program must disclose significant financial interests (including those of the investigator’s spouse and dependent children) related to their institutional responsibilities. This requirement includes Investigators (and any other individuals) responsible for design, conduct or reporting of research or educational programs.

Financial Disclosure at the Proposal Stage

A Financial Conflict of Interest (FCOI) Form must be completed by all investigators as part of the grant proposal clearance process. There are two forms that are used depending on the source of funding.

• Governmental sponsors – CSUDH Proposal Approval Form

• Non-governmental sponsors - California Form 700-U is required

Financial Disclosure When the Award/Contract is Issued

• Governmental sponsors – CSUDH Disclosure of Financial Interests Certification Form
• Non-governmental sponsors - California Form 700-U is required.

Financial Disclosure Required Throughout Grant/Contract Cycle

• Public Health Service (PHS) Projects and Non-PHS Agencies (For complete list, click HERE) using the PHS FCOI regulations - Annually and within 30 days of discovering or acquiring a new financial conflict of interest. 
• Non- PHS Governmental sponsors – Within 30 days of discovering or acquiring a new financial conflict of interest. 
• Non-governmental sponsors – Annually and within 30 days of discovering or acquiring a new financial conflict of interest.

Management of Financial Conflict of Interest

If a potential conflict of interest is disclosed, the Dean of Graduate Studies and Research will review and consult with the chair of the Academic Senate making a recommendation as to how a management plan should be developed to reduce or eliminate potential conflicts of interest.

Training Required of all PIs when Funded

For grants and projects that are funded, all Investigators must complete and document specific FCOI educational requirements before expending any awarded funds. An email will be sent with instructions on how to access the online training. Investigators will automatically receive reminders to be trained every three years once entered into the training system.

Beginning November 1, 2021, PIs must complete the CITI Program Conflict of Interest training prior to award acceptance. Beginning July 1, 2022, PIs will need to complete this training prior to proposal submission.

Additional Training for Public Health Service (PHS) Projects

Effective August 25, 2012, all investigators funded by NIH (or any other Public Health Service (PHS) Division) must undergo additional FCOI training prior to engaging in the funded research activity. Details regarding these regulations are at: http://grants.nih.gov/grants/policy/coi/ . The on-line training can found at: http://grants.nih.gov/grants/policy/coi/tutorial2011/fcoi.htm. Upon completion a certificate of completion should be forwarded to the Research Compliance Coordinator.

Additional Student/Post-Doc Training Required for NSF-Funded Projects

Effective January 4, 2010, the National Science Foundation (NSF) requires appropriate training in the responsible conduct of research (RCR) to undergraduates, graduate students, and postdoctoral researchers participating in a research project supported by NSF. Faculty Principal Investigators are not required to take this training, but may wish to do so.

Once a NSF proposal is funded, if students or postdoctoral trainees are supported by NSF to “participate in research”, the Principal Investigator will be notified to require the student to complete RCR training. Here are the instructions on logging onto the website.

(1) https://nationalethicscenter.org/login?return=L3JjcnR1dG9yaWFsLw

(2) Select “Create and Account” under New Users

(3) Complete the new users form - Go to the Ethics CORE website: http://nationalethicscenter.org/ and register.   The “Organization or School” is The National Science Foundation. It is suggested that you choose “Learning about subject matter” as reason for the account. Activate your newly created account by responding to the confirmatory email. Go to the “Personalize” tab and to groups to join a new group. The group name is “CSUDH Users”.   The group ID is “csudh”. The group title is “CSUDH Users” Once you have joined the group, go to the “RCR Modules” tab and begin the online training.

(4) Notify the Research Compliance Coordinator when you have completed training.

Throughout the duration of the NSF-funded grant, the Investigator is required to notify the Graduate Studies and Research Coordinator when new students are hired.