Financial Conflict of Interest

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Last Updated: Oct 24, 2024, 12:42 PM

Financial Conflict of Interest Committee

The purpose of the FCOI committee is to assist with the implementation of the university's Financial Conflicts of Interest on Federal Grants policy. Members of the committee meet on second Thursday of the month. Committee members represent a wide range of disciplines and schools across campus and have significant demonstrated experience with grants.

Financial Conflict of Interest Policy

The FCOI policy was established to promote objectivity in research by establishing standards that provide a reasonable expectation that the design, conduct, and reporting of research funded by federal grants or cooperative agreements will be free from bias resulting from investigator financial conflicts of interest. 

FCOI Disclosure Statement

The FCOI disclosure statement must be completed by all investigators, including the principal investigator, co-investigators, and any other staff member who is responsible for the design, conduct or reporting of project activities. The form must be submitted to the Office of Sponsored Projects Administration with the grant application prior to submission for external research support.

FCOI Training

Investigators on projects funded with federal dollars are required to complete financial conflict of interest training prior to the release of grant funds. In the case of current federally funded projects, training must completed or updated prior to the release of any additional funds. The training is provided through the Collaborative Institutional Training Initiative (CITI) and is valid for four years.  

To access the training module, please refer to CITI Training Instructions. 

Frequently Asked Questions

Below you'll find answers to the most commonly asked FCOI questions. For additional information, please contact the Office of Research Compliance at orc@siu.edu or 618-453-4530.

Who Is Considered an Investigator?

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.

How Is a Financial Interest Defined?

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

What Is a Significant Financial Interest (Sfi)?

  1. A 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 U.S. Federal, state, or local government agency, a U.S. institution of higher education, a U.S. academic teaching hospital, a U.S. medical center, or a U.S. research institute that is affiliated with an institution of higher education. 

When Do I Need to Submit or Update a Financial Disclosure?

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. 

SIUC FCOI Policy

SIUC FCOI policy applies to all faculty and other staff involved in federally funded research. This policy is applicable to all funded sponsored project activity at SIU including federal flow-through projects, where the funding agency requires an FCOI disclosure.

The SIUC FCOI policy is distinct from, supplements, and is in to addition to the general “Conflict of Interest: Non-University Activities and Financial Interests” policy which is applicable to the general duties of university staff, faculty, and administration while acting as employees of the University.