FCOI FAQs | Office of Research Compliance | SIU

Investigator means the project director (PD), or principal investigator (PI), co-principal investigator (Co-PI), and any other key personnel, regardless of title or position, who is responsible for the design, conduct, or reporting of federally funded research, which may include for example, collaborators or consultants.

Financial interest means anything of monetary value, whether or not the value is readily ascertainable.

1. Significant financial interest exists if the following situations apply to the investigator and/or the investigator's spouse or domestic partner as evidenced by registration or certification as a same-sex partner, children, and immediate relatives (siblings and parents) involving companies that reasonably appear to be related to the proposed research:
   1. For publicly traded companies, if income in excess of $5000 (in the aggregate) is received during the twelve months preceding the disclosure. Examples of income include salary, consulting fees, honoraria, paid authorship, stock, stock options, or other ownership interests (based on public prices or other reasonable measures of fair market value).
   2. For non-publicly traded companies, if income in excess of $5000 (in the aggregate) is received during the twelve months preceding the disclosure, or when any equity interest is held (e.g., stocks, stock options, or other ownership interests).
   3. If any income is received from intellectual property rights and interests (e.g., patents, copyrights).
2. Any travel paid for by any entity other than a Federal, state, or local government, an institution of higher education, an academic teaching hospital, a medical center, or a research institute associated with an institution of higher education must be disclosed. Upon review, further information may be requested including a determination or disclosure of monetary value, in order to determine whether the travel constitutes an FCOI with the federally funded research.
3. Significant financial interest does not include the following types of financial interests:
   1. Salary, royalties, or other remuneration paid by SIU Carbondale 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.
   2. Income from investment vehicles, such as mutual funds and retirement accounts, as long as the Investigator does not directly control the investment decisions made in these vehicles.
   3. Income from seminars, lectures, or other teaching engagements, or from service on advisory panels or review panels from a 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. 

At the time of submission of a grant to a federal agency, all participating investigators are required to fill out and submit a Financial Interest on Federal Grants Disclosure Statement (FCOI form) (available on the OSPA website). In addition, all investigators must submit an updated FCOI form annually during the period of the award (by deadlines established by OSPA) to include any information that was not disclosed previously to SIU Carbondale, and to include updated information regarding any previously disclosed significant financial interest (e.g., the updated value of a previously disclosed equity interest). Any newly discovered or acquired significant financial interest (e.g., through purchase, marriage, or inheritance) must be disclosed within thirty days.  New Investigators added to a project after the start date of the project must also complete a disclosure form.  This includes situations where a non-Investigator employee’s status is changed to that of Investigator.