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1. Disclosure: Significant Financial Interests
In accordance with the University Policy on Financial Conflict of Interest in Research (FCOIR) and relevant sponsor regulations, significant financial interests (SFIs) of you and your family must be disclosed to the University of Illinois at the time when your funding proposal is submitted to the University. You must update your disclosure annually and within 30 days of any newly acquired or discovered SFIs or changes in the reported SFIs on awarded grants (regardless of the type of award, including federal flow through) and extensions (with or without funding).
Go to UIC Research COI to update your Disclosure Profile.
What regulations and University or sponsor requirements does this satisfy?
This disclosure satisfies the requirements of:
Public Health Services (PHS): The Public Health Service Regulation 42 CFR Part 50, Promoting Objectivity in Research, requires investigators to disclose SFIs and sponsored or reimbursed travel. An “Investigator” is defined as the project director or principal investigator or any other person, regardless of title or position, who is responsible for the design, conduct, or reporting of the sponsored research or proposed sponsored research, which may include, for example, collaborators or consultants.
National Science Foundation (NSF): The National Science Foundation in its Award and Administration Guide, February 2014, requires investigator – anyone responsible for design, conduct, or reporting of the research or educational activities funded by NSF – must disclose SFI held personally or by the investigator’s spouse or dependent children.
Your Disclosure Profile in UIC Research COI should follow the guidelines explained below. Your disclosure will be evaluated in accordance with the University FCOIR Policy and consistent with the requirements of the funding agency.
Other sponsors and Institutional Review Board: This disclosure and management plan process is used when a conflict of interest is identified related to University research. This process satisfies the COI compliance required by other sponsors per the sponsor’s terms of award and the Institutional Review Board for each campus.
What is a "Significant Financial Interest (SFI)?"
A Significant Financial Interest (SFI) (42 CFR 50.603) is identified when:
- The value of any remuneration received from an external entity at present or in the 12 months preceding the disclosure that when aggregated for the individual, one’s spouse or dependent children totals or exceeds $5,000. The $5,000 threshold also applies to salary, royalties, and other payments aggregated for the individual, one’s spouse and dependent children.
- Publicly-traded equity if the value of the equity (plus any remuneration) meets or exceeds $5,000.
- Any level of ownership of privately-held equity regardless of the dollar value.
Per NSF Guidelines: Significant Financial Interest (SFI) is anything of monetary value, including, but not limited to, salary or other payments for services (e.g., consulting fees or honoraria); equity interest (e.g., stocks, stock options or other ownership interests); and intellectual property rights (e.g., patents, copyrights and royalties from such rights).
What are some examples of significant financial interests that are required to be reported?
Financial Interest Examples Thresholds for SFI Remuneration, income, salary, and any payment for services Consulting fees, honoraria, paid authorship $5,000 or more Public equity interest Stock, stock option, or other ownership interest Present day market value of $5,000 or more Private equity interest Stock, stock option, or other ownership interest Any ownership interest regardless of percentage or dollar value Intellectual Property (IP) rights and interests Patents not assigned to the University of Illinois; licenses from the University of Illinois to an external entity; copyrights; royalties that are not paid by the University of Illinois When profit or remuneration from IP interests meets or exceeds $5,000 Fiduciary role Executive role, a voting member of the board Report fiduciary relationships (even if unpaid) that may be reasonably related to your research or University responsibilities; or with an entity that does business with the University. Sponsored or reimbursed travel Travel paid by an external entity (including airfare, gas, car rental, hotel room, meals, stipends, etc). Travel must be reported from any entity unless the travel is reimbursed or sponsored by a federal, state, or local government agency, an Institution of higher education as defined by 20 U.S.C. 1001(a); an academic teaching hospital, a medical center, or a research institute that is affiliated with an Institution of higher education. $5,000 de minimis for reporting. Foreign Financial Interests Financial interests received from a foreign Institution of higher education or the government of another country (which includes local, provincial, or equivalent governments of another country). $5,000 or more.
What interests are exempt from this reporting requirement?
The PHS regulation (42 CFR 50.603) exempts the following significant financial interests and reimbursed or sponsored travel from the reporting requirements:
- salary, royalties or other remunerations paid by the University of Illinois; including intellectual property rights assigned to the University of Illinois and agreements to share royalties related to such rights;
- income from investment vehicles (mutual funds or retirement account that are not managed directly by the individual);
- income from seminars, lectures, or teaching engagements sponsored by a US federal, state, or local government agency, an US Institution of higher education as defined by 20 U.S.C. 1001(a); an academic teaching hospital, a medical center, or a research institute that is affiliated with a US Institution of higher education;
- income from service on advisory committees or review panels for a US federal, state, or local government agency, an US Institution of higher education as defined by 20 U.S.C. 1001(a). (e.g., NIH review panel);
- travel that is reimbursed or sponsored by a US federal, state, or local government agency, an US Institution of higher education as defined by 20 U.S.C. 1001(a); an academic teaching hospital, a medical center, or a research institute that is affiliated with a US Institution of higher education.
The term Significant Financial Interest per NSF policy does not include:
- salary, royalties or other remuneration from the applicant organization;
- any ownership interests in the organization, if the organization is an applicant under the Small Business Innovation Research Program or Small Business Technology Transfer Program;
- income from seminars, lectures, or teaching engagements sponsored by public or non-profit entities;
- income from service on advisory committees or review panels for public or nonprofit entities;
- an equity interest that, when aggregated for the investigator and the investigator’s spouse and dependent children, meets both of the following tests: does not exceed $10,000 in value as determined through reference to public prices or other reasonable measures of fair market value, and does not represent more than a 5% ownership interest in any single entity; or
- salary, royalties or other payments that, when aggregated for the investigator and the investigator’s spouse and dependent children, are not expected to exceed $10,000 during the prior twelve-month period.
Non-UI Affiliates Request to Access UIC Research COI
Non-UI Affiliates that needs to access UIC Research COI should use the Job Aid for instructions how to obtain NetID to use UIC Research COI.
2. FCOI Training
To comply with the 2011 Public Health Services (PHS) Regulations, Department of Health and Human Services (HHS) 42 CFR Part 50 and 45 CFR Part 94, on Financial Conflicts of Interest (FCOI), Investigators on HHS/PHS/NIH awards must complete a University-approved Financial Conflict of Interest training prior to engaging in PHS-funded research and thereafter, every four years and immediately when any of the following circumstances apply:
- The University revises the Policy of Conflict of Commitment and Interest and procedures in any manner that affects the requirements of the Investigator to comply with the Regulation;
- An Investigator is new to the University of Illinois;
- The University finds that an Investigator is not in compliance with the University’s Policy on Conflicts of Commitment and Interests or with the University-approved management plan.
If you are an Investigator on an existing award, training must be completed prior to the continuing review of the award. Online training can be accomplished at UIC Research COI.
3. Verifying Investigator COI Training and Disclosure
When a study is sponsored by a federal agency, including federal flow through, or an organization that follows the 2011 PHS regulations (see list of agencies), then the principal investigator or business/project manager can monitor the verification of Investigator COI training and disclosure by using the Custom Report “Verify Investigator COI Training and Disclosure” in UIC Research COI custom reports tab.
External Mentor FCOI Compliance Verification
External mentor verification form is available at: https://go.uic.edu/ExternalMentor_VerifyFCOI
The UIC PI should work with external mentors to complete the verification form with the external mentor’s authorized representative. Completed forms should be sent to the COCI Director, Jacquelyn Jancius, firstname.lastname@example.org and COCI Coordinator, Scott MacEwen, email@example.com. The UIC PI should also retain a copy of the verification form for the project records.
The COCI Office will review the completed external mentor verification form and confirm the compliance requirements are met. When compliance requirements are not met, the COCI Office will provide guidance on how an external mentor may use UIC Research COI to complete their training and disclosure.
4. Sub-recipient Compliance
In accordance with 42 CFR Part 50 SubPart F and 45 CFR Part 94, all investigators participating in the project must comply with the written policies of the contractor relating to the disclosure of Significant Financial Interests which may constitute or may be perceived to constitute a Financial Conflict of Interest affecting the design, conduct or reporting of the project. The contractor will report to UIC within 30 days of determining that such a financial conflict of interest pertinent to the project exists.
If the contractor does not have a financial disclosure policy consistent with 42 CFR Part 50 SubPart F and cannot provide such certification, the contractor’s investigators will be subject to the University of Illinois financial conflicts of interest policy for disclosing significant financial interests that are directly related to the subrecipient’s involvement in the project and training.
- Subrecipient Financial Conflicts of Interest Certification Form
PI or business manager should use this form at the time of proposal for HHS, PHS, NIH sponsored research or any other non-federal agency that applies the PHS FCOI regulations when there will be a sub-award.
- FDP Clearinghouse for COI
Federal Demonstration Partnership Clearinghouse for the PHS FCOI regulations.Business managers can check when an institution has registered with the FDP Clearing to verify if the institution attests that it has a policy that complies with the 2011 PHS FCOI regulations. If an institution is not listed, please complete the Subrecipient Financial Conflict of Interest Certification form.
- Subrecipient Financial Conflicts of Interest Certification Form