Who is an Investigator?
Investigator is defined as “The principal investigator and any other person (regardless of title or position) who is responsible for the design, conduct or reporting of research or educational activities. This may include faculty and research staff (research associates and assistants, postdoctoral fellows, graduate students, visiting scientists engaged in research conducted at the University) as well as consultants.”
What are considered my institutional responsibilities?
Institutional Responsibilities means an investigator’s professional responsibilities on behalf of the institution which may include research, research consultation, teaching, professional practice, institutional committee memberships, and service on panels such as Institutional Review Boards or Data and Safety Monitoring Boards.
What is a Financial Conflict of Interest?
Financial Conflict of Interest (FCOI) means a situation in which significant financial interests in a business, or other personal considerations provided by a business, may compromise, or have the appearance of compromising, an Investigator's professional judgment in conducting or reporting research, the results of which could affect the aforementioned business, either directly or indirectly. An FCOI exists when the University, through its designated official(s), reasonably determines that an Investigator's Significant Financial Interest (SFI) is related to a research project and could directly and significantly affect the design, conduct or reporting of the research.
What is a Significant Financial Interest, as defined by PHS?
Each Investigator must disclose his/her known SFIs (including those of the Investigator’s Immediate Family) that reasonably appear to be related to the Investigator’s Institutional Responsibilities (including those that would reasonably appear to be affected by the research for which funding is sought or are in entities whose financial interests would reasonably be affected by the research). In determining whether a financial interest has to be disclosed, the Investigator shall consult the definition of SFI within the University policy and, if in doubt, resolve in favor of disclosure.
- With regard to any publicly traded entity, an SFI exists if the value of any remuneration* received from the entity in the twelve months preceding the disclosure and the value of any equity interest in the entity as of the date of disclosure, when aggregated, exceeds $5,000; or
- With regard to any non-publicly traded entity, an SFI exists if the value of any remuneration received from the entity in the twelve months preceding the disclosure, when aggregated, exceeds $5,000, or when the Investigator (or the Investigator’s Immediate Family) holds any equity interest (e.g., stock, stock option, or other ownership interest); or
- Intellectual property rights and interests (e.g., patents, copyrights), upon receipt of income related to such rights and interests.
- Investigators also must disclose the occurrence of any reimbursed or sponsored travel (i.e., that which is paid on behalf of the Investigator and not reimbursed to the Investigator so that the exact monetary value may not be readily available), related to their Institutional Responsibilities.
*For purposes of this definition, remuneration includes salary and any payment for services not otherwise identified as salary (e.g., consulting fees, honoraria, paid authorship); equity interest includes
any stock, stock option, or other ownership interest, as determined through reference to public prices or other reasonable measures of fair market value
When do I disclose significant financial interests?
A financial disclosure must be filed:
- Once every 12 months
- Within 30 days of acquiring or discovering a new financial interest
- Within 30 days of any reimbursed or sponsored travel
What does not need to be disclosed?
Disclosure is not required for:
- Income from seminars, lectures, or teaching engagements sponsored by (and service on advisory committees or review panels for) a federal, state, or local government agency, an Institution of higher education as defined at 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.
- Salary, royalties, or other remuneration paid by the Institution to the Investigator if the Investigator is 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.
What is the University’s Conflict of Interest in Research Policy?
It is critical that the design, conduct, or reporting of research at the University not be compromised by the conflicting financial interests of an investigator. Investigators' financial interests must be disclosed and reviewed by the Financial Conflict of Interest in Research Committee (FCOIRC). You can see the Policy in its entirety at http://policy.uconn.edu/?p=382.
Why do I need to fill out a disclosure?
The University is obligated by federal and state laws and regulations to identify, manage, reduce, and if possible, eliminate any potential conflict of interest.
For additional information, please also visit the NIHs FAQ regarding the implementation of the revised PHS FCOI regulations for grants and cooperative agreements.