Financial Conflict of Interest


Financial Conflict of Interest Policy for Public Health Services Funded Projects

Pittsburg State University is committed to maintaining a research environment that promotes attention to the highest ethical standards for research. This commitment includes compliance with regulatory requirements set forth by the Public Health Service (PHS), the National Science Foundation (NSF), and other regulatory and ethical bodies. It is the responsibility of the University to promote objectivity in research through the establishment of a Financial Conflict of Interest (FCOI) Policy.

Occasionally, situations arise where an investigator may have an outside financial interest that could conflict or be perceived to conflict with his or her research conducted on behalf of Pitt State. To address these situations and to comply with federal regulations and sponsor requirements, the University has adopted a policy regarding financial conflicts of interest. The foundation of this policy involves annual conflict of interest certification, disclosure of such interests when they reach regulatory thresholds, the appropriate updating of these certifications, managing these conflicts in a way that ensures the integrity of the research, and FCOI training once every four years.

Please note that this policy is specific to Institutional Compliance Integrity (ICI) Financial Conflict of Interest requirements for investigators and does not replace the employee disclosures and certifications required by the Kansas Board of Regents (KBOR), the State of Kansas and Pitt State.

Financial Conflict of Interest Policy for Public Health Services Funded Projects

 

In compliance with federal regulation 42 CFR Part 50, Subpart F, Promoting Objectivity in Research, Pittsburg State University requires investigators who work on or submit project proposals to Public Health Services-compliant agencies (PHS) to disclose their personal Significant Financial Interests (SFI), and those of their spouse and dependent children, related to their institutional responsibilities.  This includes the Principal Investigator, Co-Investigators, Senior and Key Personnel, and any other individual who is responsible for the design, conduct, or reporting of research funded by PHS or an agency or organization that follows PHS disclosure requirements.  Additionally, PHS FCOI Disclosure forms shall be filed for new SFIs and updated information from a previously disclosed SFI, as soon as such situations become known, and in any instance, not later than thirty (30) days after discovery or acquisition of the SFI.

Financial Conflict of Interest Disclosure for Public Health Services Funded Projects

 

Financial Conflict of Interest Training

Investigators engaging or planning to engage in PHS funded research must complete FCOI training on investigator responsibilities prior to engaging in PHS-funded research and at least once every four (4) years. Award funds for PHS-compliant projects must be withheld until all project investigators have completed the FCOI training course with a passing score of 80%.

FCOI training is completed through CITI Program Training. To access CITI Program Training, go to the GUS Portal and login using your Pitt State credentials. The Login button is at the top right of the portal. Once logged in, enter CITI in the search box and select CITI Program. You will then be able to login to your existing account or register for an account. Please use your Pitt State email address when registering.

 

Funding Agencies and Organizations that Require FCOI

U.S. Public Health Service (PHS) Agencies include:

  • National Institutes of Health (NIH)
  • Food and Drug Administration (FDA)
  • Centers for Disease Control and Prevention (CDC)
  • Agency for Healthcare Research and Quality (AHRQ)
  • Agency for Toxic Substances and Disease Registry (ATSDR)
  • Center for Medicaid and Medicaid Services (CMS)
  • Department of Health and Human Services (DHHS)
  • Health Resources and Services Administration (HRSA)
  • Indian Health Service (IHS)
  • Substance Abuse and Mental Health Services Administration (SAMHSA)

Some non-federal organizations also follow PHS disclosure requirements for FCOI compliance, such as the American Heart Association, American Cancer Society, Susan G. Komen for the Cure and others. Check with Institutional Compliance Integrity if you are not certain.

 

Other Resources

  

Policies and Reporting

The Kansas Board of Regents (KBOR) and Pitt State policies require that all university employees (except student employees and graduate students) complete and submit a yearly report of financial interests and time commitments. All University employees must complete a disclosure even if the employee is not involved in sponsored program activity and/or no conflicts of time interest.

 

KBOR Policies

  • Commitment of Time, Conflict of Interest, Consulting and Other Employment, KBOR Policy Manual, Chapter II, C., 12.
  • In adherence to the KBOR Conflict of Interest policy, all faculty and unclassified staff must complete an annual reporting of consulting arrangements, significant financial or managerial interests and outside employment. Learn more about the policy and reporting requirements in Chapter 4 of the Pittsburg State University Faculty and Unclassified Personnel Handbook.