Comply with Financial Conflict of Interest Policy (PHS)

Research, Sponsored Projects   |   Approved October 9, 2015

Purpose

To implement and to comply with U.S. Public Health Service (PHS) regulations promoting objectivity in research.

Applicability

Primary Investigator or designee planning to participate in, or who is participating in, a sponsored project funded by the PHS. “Investigator” as used in this procedure means the project director or principal investigator and any other person, regardless of title or position, who is responsible for the design, conduct, or reporting of research funded by the PHS, or proposed for such funding, which may include, for example, collaborators or consultants. 

All PHS funded agencies and offices are covered under the Financial Conflict of Interest (FCOI) policy. These are:

• National Institutes of Health (NIH)
• Food and Drug Administration (FDA)
• Substance Abuse and Mental Health Services Administration (SAMHSA)
• Agency for Healthcare Research & Quality (AHRQ)
• Agency for Toxic Substances and Disease Registry (ATSDR)
• Centers for Disease Control and Prevention (CDC)
• Health Resources and Services Administration (HRSA)
• Indian Health Service (IHS)
• Office of Global Affairs (OGA)
• Office of the Assistant Secretary for Preparedness and Response (OASPR)
• Office of the Assistance Secretary for Health (OASH)

Instructions

1. Complete training prior to engaging in PHS-funded research. The online training module is available through CITI training; for information, see the Office of Accountability and Compliance website.
   1. Training must be repeated at least every four years.
2. Disclose before the time of submission of an application for PHS-funded research and annually during the period of the PHS-funded research award.
   1. In addition, Investigators must disclose within 30 days of acquiring a new significant financial interest.
   2. Disclosure is made using the SFI Disclosure Form and is submitted to the University of Maryland, Baltimore (UMB) Conflict of Interest Officer.
3. Compliance with training and disclosure requirements may be reviewed through the PHS. (UMB log-in is required.)