To comply with 42 CFR Part 50 Subpart F, the UO developed Policy II.06.01 Financial Conflict of Interest in Research Policy (FCOI Policy). The FCOI Policy upholds the UO’s commitment to research objectivity and applies to all sponsored research, regardless of whether the sponsor is federal.
Institutional Responsibilities under the FCOI Policy
The UO must:
- Review investigators’ disclosures of Significant Financial Interests and determine if they present actual or potential conflicts in research
- Manage financial conflicts of interest in research in accordance with 42 CFR Part 50 Subpart F, sponsor requirements, and all other applicable federal and state requirements
- Report identified conflicts to sponsors before any project spending
- Notify sponsors if bias is discovered in the design, conduct, or reporting of sponsored research in accordance with 42 CFR Part 50 Subpart F, sponsor requirements, and all other applicable federal and state requirements
- Maintain institutional records related to the policy and its procedures
Investigator Responsibilities under the FCOI Policy
Investigators responsible for the design, conduct, or reporting of research who receive sponsored research awards must:
- Disclose Significant Financial Interests annually for themselves, their spouse, and their dependent children related to their institutional responsibilities
- Disclosures must be on file prior to submitting a sponsored research proposal.
- Disclose new or changed Significant Financial Interest within 30 days
- Complete financial conflict of interest training before any spending on a sponsored award
- Training is valid for 3 years.
Learn More About What to Disclose
Subcontractors and Subawardees Under the FCOI Policy
All subrecipients on UO awards must have an enforced financial conflict of interest (FCOI) in research policy to comply with federal regulations and UO policy. If not, they must follow UO's FCOI Policy.
Under the UO's policy, subrecipient personnel responsible for the design, conduct, or reporting of research must:
- Complete FCOI training every 3 years
- Disclose annually all Significant Financial Interests for themselves, their spouse, and their dependent children related to their institutional responsibilities.
- Update disclosures within 30 days of acquiring or changing a Significant Financial Interest
Learn More About Subaward Requirements
Sponsor-specific Requirements
Most federal sponsors require researchers to submit biographical sketches and Current and Pending or Other Support documents as part of their proposals.
A biographical sketch documents a researcher’s qualifications and experience for a specific role in a project. In general, the document includes a researcher’s organizational affiliations and appointments; academic, professional, or institutional appointments; professional preparation; and (sometimes) products.
A Current and Pending or Other Support document provides the sponsor with information about resources made available to a researcher in support of their research, both currently active and proposed for the future. This document helps the sponsor assess the researcher’s capacity to carry out the proposed project or identify any potential conflicts of commitment. It also helps the sponsor assess any potential scientific and budgetary overlap or duplication with the project being proposed.