Financial Conflict of Interest

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The “Financial Conflict of Interest on Federal Grants Policy” was designed 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. It applies to all faculty and other staff involved in federally funded research. This policy was crafted in response to federal regulations that require that all investigators disclose any potential financial conflict of interest (FCOI) to the university prior to undertaking 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.

This policy is distinct from, supplements, and is in 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.  See the University's Financial Conflict of Interest on Federal Grants Policy.

Required Training for Investigators of Federal Research Grants

(Effective August 24, 2012)

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 the training will need to be completed prior to the release of any additional funds. The training is provided through the Collaborative Institutional Training Initiative (CITI).  

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


Financial Interest on Grants Disclosure Statement (pdf)

This form 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 application prior to submission for external research support.

The SIU Carbondale Financial Conflict of Interest (FCOI) Policy applies to any granting agency that requires an FCOI disclosure.  As of March 2015, these agencies include:

  • Public Health Services, including NIH, CDC, HRSA, SAMHSA, FDA, and CMS.
  • National Science Foundation
  • American Cancer Society
  • American Heart Association

Additional agencies may require disclosure at any time, including prime awardees where SIUC is a subcontractor.