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Managing Conflicts of Interest Training Plan for U.S. Public Health Service Related Grants and Contracts

In accordance with the 2011 Revised Financial Conflict of Interest (FCOI) Regulation, Promoting Objectivity in Research (42 CFR Part 50 Subpart F), the following provides training guidelines to insure compliance with this regulation for U.S. Public Health Service (PHS) related grants and contracts, including those from the National Institutes of Health (NIH).

Each investigator as defined in the University FCOI policy must complete mandatory FCOI training (link provided below) prior to engaging in research related to any PHS-funded grant or contract (including those from NIH) and at least every FOUR YEARS, and immediately under the circumstances such as:

  • Institutional FCOI policies change in a manner that affects investigator requirements;
  • An investigator is new to an institution; or
  • An institution finds an investigator noncompliant with its FCOI policy or management plan.

To meet this requirement, investigators will complete the Conflict of Interest Tutorial located on the NIH website. This tutorial can be found at https://grants.nih.gov/grants/policy/coi/tutorial2018/story_html5.html 

At the end of the tutorial is a certificate of completion. Each investigator will print one copy, sign and date it, and send it to the Office of Sponsored Programs (OSP). A copy of this certificate MUST be on file in OSP before expenditures can be made from any PHS-related grants and contracts, including those from the NIH.

The institutional FCOI policy related to sponsored programs can be found at bulldog.swosu.edu/administrative-services/sponsored-programs/info/conflicts-policy.aspx.  Other institutional conflict of interest information can be obtained from the SWOSU Human Resources office.

This training will be required of investigators applying for and receiving PHS-related grants and contracts, including those from NIH, as of August 25, 2012.