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.
Subcontractors and Subawardees under the FCOI Policy
Subcontractors and subawardees who do not have their own enforced financial conflict of interest in research policy must follow the UO’s.
Sponsor-specific Requirements
Many federal sponsors align with 42 CFR Part 50 Subpart F, but may have unique requirements.
- National Science Foundation: See the Proposal and Award Policies and Procedures Guide
- National Institutes of Health: See the NIH policy website
- Department of Energy: See the DOE’s conflict of interest policy requirements for financial assistance
- The Department of Energy requires all research participants—not just PIs or senior/key personnel —to complete a financial conflict of interest disclosure and training. This requirement includes graduate and undergraduate students listed on the budget. Staff in the Conflict of Interest Office will contact PIs of DOE-funded projects that have this broader requirement.
- National Aeronautics and Space Administration (NASA): See NASA’s grants policies and compliance requirements
Always review your specific award’s terms and conditions for financial conflict of interest requirements.