The Required Steps in the Conflict of Interest Disclosure Process are provided below:
- How do I disclose my outside activities and financial interests (and those of my spouse and dependent children) to the University?
University employees are to continue to make those disclosures on the Division of Human Resources Report of Outside Activity/Conflict of Interest web based portal here (the OA/COI Electronic Portal). Individuals who are not University employees (e.g subcontractors, consultants or collaborators) should contact the Office of Research and Economic Development for further guidance. The questions on the OA/COI Electronic Portal have been updated to capture the new disclosure requirements of Florida Statute Section 1012.977.
- When must I disclose my outside activities and financial interests?
Your disclosure in the OA/COI Electronic Portal is due no later than the time a proposal for a sponsored research project is submitted to the Office of Research and Economic Development (ORED) for review, and must be updated annually by September 30 thereafter. Additionally, you must update your disclosure if you wish to engage in a new outside activity and within thirty days of discovering or acquiring (e.g., through purchase, marriage, or inheritance) a new financial interest.
- Are there any changes as to who is required to disclose their outside activities and financial interests and what must be disclosed?
Yes. Outside activity/financial interest disclosures are now required for all FIU employees engaged in the design, conduct or reporting of sponsored research, including collaborators, students, etc. if they are employed by FIU). The outside activities and financial interests that must be reported are delineated in the updated Conflict of Interest in Research policy and the OA/COI Electronic Portal questions have been revised to capture the required disclosures in accordance with Florida Statute Section 1012.977.
- What travel must be reported?
Investigators must disclose the sponsorship of their travel if the travel relates to the Investigator’s Institutional Responsibilities. However, no travel disclosure is required if the travel is paid for by any of the following entities if they are United States entities:
- a federal, state, or local government agency;
- an institution of higher education or a research institute affiliated with an institution of higher education;
- an academic teaching hospital;
- a medical center.
You must disclose the travel sponsorship both: (1) when you know the amount of reimbursement or payment for the travel; and also (2) when the travel is paid on your behalf but you don’t know the monetary value. The travel details which must be disclosed are:
- purpose of the trip,
- identity of the travel sponsor/organizer,
- destination and duration.
Again, the questions on the OA/COI Electronic Portal capture the travel information that is required.
- On the Outside Activity/Conflict of Interest report, in the research section 1.J, do I need to report, as an Investigator, mutual funds or retirement accounts that I, my spouse or dependent children have/has?
Please see the instructions to section 1.J, which are also included in the Conflict of Interest in Research Policy #2370.005 which state:
Please note that the following types of financial interests are not deemed to be SFIs under the federal regulations and therefore need not be disclosed in connection with your answers to the questions below:
- salary, royalties, or other remuneration paid by the University to you if you are currently employed or otherwise appointed by the University, including intellectual property rights assigned to the University and agreements to share in royalties related to such rights;
- income from investment vehicles, such as mutual funds and retirement accounts, as long as you, your spouse or dependent children do not directly control the investment decisions made in those vehicles;
- income from seminars, lectures, or teaching engagements sponsored by any of the following United States entities: Federal, state, or local government agency, an institution of higher education, an academic teaching hospital, a medical center, or a research institute that is affiliated with an institution of higher education (income from foreign entities must be reported); or
- income from service on advisory committees or review panels for any of the following United States entities: Federal, state, or local government agency, an institution of higher education, an academic teaching hospital, a medical center, or a research institute that is affiliated with an institution of higher education (income from foreign entities must be reported).
Therefore, if the parameters above are met, you do no need to report those financial interests.
- How will subrecipient disclosures be handled?
A Subawardee Commitment Form is required for each proposed subawardee (subcontractor, consultant, collaborator) on a proposal. Among the questions to be answered by the subawardee on that Form is whether the subawardee has a policy on financial conflicts of interest that complies with applicable PHS regulations. If the answer is “yes”, no further disclosure is required from the subawardee. If the answer is “no”, then each subawardee Investigator on the proposed project must make their disclosures of outside activities/financial interests to FIU and those disclosures must be reviewed by FIU in the same manner that FIU reviews the disclosures of FIU employees.
- Must students working on sponsored research projects disclose their outside activities and financial interests to FIU?
Yes, pursuant to the definition in the FIU Conflict of Interest in Research Policy #2370.005 at https://policies.fiu.edu/policy/572.The State of Florida financial conflict of interest regulations as codified in Florida Statute Section 1012.977 (and FIU policy #2370.005) requires disclosures, and University review, of outside activities and financial interests of employees engaged in the design, conduct or reporting of sponsored research.
- If I submitted a proposal through ORED and answered the COI questions on the ePRAF, do I need to answer these questions again the ROA/COI Employee portal?
The questions on the ePRAF are designed to ascertain whether there are any conflicts associated with the specific proposal, when the last date of your disclosure was on the ROA/COI portal, whether you have had any material changes since your last disclosure and if you took any required COI training. The ePRAF is not the official system of record for outside activities or conflicts of interest disclosures. All outside activities and potential conflicts of interest need to be disclosed on the ROA/COI portal.
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II. Review of Disclosures, Management and Reporting
- What is the process in (ORED) for reviewing outside activity/conflict of interest disclosures on proposals and awards?
ORED has established the following processes to ensure compliance with the updated conflict requirements:
Please refer to the Conflict of Interest Process webpage for more information.
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III. Additional Requirements
- Do I need to be trained on Conflict of Interest requirements?
Yes. Pursuant to the Conflict of Interest in Research policy, and in accordance with PHS requirements,
“each Investigator must complete training on this policy, the Investigator’s responsibilities regarding disclosure of SFI and PHS regulations regarding financial conflicts of interest:
(1) prior to engaging in any PHS-funded research and
(2) at least every four years thereafter; and
(3) immediately when any of the following circumstances apply:
a. the Investigator requirements of this policy are revised;
b. an Investigator is new to an Institution; or
c. FIU finds that an Investigator is not in compliance with this policy or a management plan. “
Click here to access information about Conflict of Interest online training.
- Are there any additional conflict of interest requirements that apply to me?
Yes. In addition to the Conflict of Interest in Research policy, the University has conflict of interest policies unrelated to research that apply to all faculty and staff members. All employees of Florida International University are subject to the Florida Code of Ethics for Public Officers and Employees which is found in Part III, Chapter 112, Florida Statutes. The OA/COI Electronic Portal captures both research and non-research related disclosures.
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IV. List of Organizations that require compliance with PHS FCOI regulations
- Please visit https://thefdp.org/default/fcoi-clearinghouse/fcoi-agencies/ for a list of agencies that have been reported to the Federal Demonstration Partnership (FDP) as using the PHS regulations (including FCOI) in their award terms. Additional sponsors that are not listed on the FDP site may also require adherence to the U.S. Department of Health and Human Services Public Health Service Financial Conflict of Interest regulations, as specified in their Award Terms and Conditions.
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