The guiding principle behind this process is intended to promote objectivity in research by defining a set of standards that provide a reasonable expectation that the design, conduct and reporting of research will be free from bias resulting from investigator (any individual responsible for the design, conduct, or reporting of research) financial conflicts of interest.
These are some key components you need to be aware of are:
- Threshold: Disclosure of significant financial interests over $5,000.
- Full Disclosure: Investigators are directed to disclose all significant interests that are related to their Institutional Responsibilities. The University’s representative will determine whether they are potential conflicts.
- Travel: The system requires that sponsored travel be included in the disclosure, regardless of value. This does not, however, include travel that is included the budget for a grant, nor for travel funded by the University.
- Training: We have developed a mandatory conflict of interest training module which must be reviewed every 4 years. See the Training section below on this page to view the mandatory training video.
- Exempted Sources: Only those payments from accredited institutions of higher education, government bodies and research institutions will be exempted.
- Public Accessibility: Certain information is required to be made available to the public concerning identified FCOIs held by senior/key personnel via a written response to any requestor within five business days of a request, and update such information as specified in the rule.
Syracuse University’s Policy on Financial Conflict of Interest requires all investigators to file an Annual Disclosure of FCOI and to update their disclosure within 30 days of the occurrence of a new reportable financial interest(s). In order to maintain a single system of disclosure for all grant applications, Syracuse University has adopted these standards for all researchers involved in externally funded research. More information regarding the applicability of the requirement is at the bottom of the page in addition to other useful resources.
Syracuse University’s Training Plan for FCOI
Syracuse University requires mandatory Training for all “Investigators” meaning “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 externally funded projects, or proposed for such funding.” Training is required prior to engaging in research related to any externally funded project and at least every four years, and immediately when any of following conditions apply: 1) The institution revises its financial conflicts of interest policies or procedures in any manner that affects the requirements of the investigators; 2) a researcher is new to the institution; or 3) when a researcher is found to be out of compliance with the regulations or with the institution’s financial conflicts of interest policy or management plan.
The goal of SU’s training modules is to introduce investigators not only to the technical requirements of the policy, but to inform them about the underlying ethical questions and to show how SU’s policies and procedures address those concerns within our own context, while remaining sensitive to the privacy of investigators.
Our training system is simple: investigators need to watch two training modules—which are embedded in the MySlice Significant Conflict Interests portal and can also be found directly below this text—and then certify on their disclosure that they have done so. In total, the training should take roughly 20 minutes and only needs to be repeated once every four years.
Financial Conflict of Interest Training Video Script
“What is the process?”
SU maintains a Financial Conflict of Interest (FCOI) portal designed to make the FCOI process as seamless and efficient as possible, while assuring compliance and achieving regulatory intent.
Both the COI questionnaire (required by SU Policy for all SU full time faculty and staff, and most part time staff) and the FCOI questionnaire (required by federal regulation and enacted in SU Policy for all *Investigators on sponsored projects) will now be accessible through the Myslice portal using the same login credentials. The submission calendar for annual disclosures begins in April.
* Investigators include “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 externally funded projects, or proposed for such funding.”
Where can I find more information?
If you have any questions, please call the Office of Research at x2492 or the Office of Sponsored Programs at x2807. For copies of official documents please follow these links:
- Syracuse University Policy and Procedures for Financial Conflicts of Interest
- Disclosure of Significant Financial Interests (SFI) form for Investigators
- The form can be accessed via Myslice by clicking the Significant Financial Interests link under the Employee Services section.
- Public Disclosure Request Forms. This form is for outside individuals seeking information on relevant conflicts of interest involving public funds. The Office of the Vice President will reply to these requests within five working days of submission.
- Other Forms: Management Plans, Public Disclosures, PHS Report, Retrospective Review Reports, Mitigation Reports
- Outside Sources: NIH Frequently Asked Questions (last revised May 18, 2012), Publication of Revised Regulations in the Federal Register, 8/25/2011, NIH Overview of FCOI Regulation and Changes, Summary of Major Changes (.doc)