All PHS-funded "investigators" must complete online FCOI training prior to the expenditure of funds on any newly-funded projects, including noncompeting continuation awards. This applies to all new PHS-sponsored research projects as of August 24, 2012. Training must be completed at least every four years.
Current PHS awards are not subject to these new requirements until the noncompeting continuation award. However, we encourage investigators to take the FCOI training now to fulfill this mandatory requirement.
PHS-funded investigators must disclose all travel reimbursements through the Financial Interest Disclosure System (FIDS) that are either sponsored by (that is paid by an outside entity directly to the investigator) or reimbursed directly to the investigator from an outside entity for travel that occurs after August 24, 2012, with some exceptions. This disclosure requirement does not apply to funding provided to the investigator via the institution (for example as part of sponsored research projects, paid from departmental discretionary or gift funds).
Exceptions include: travel reimbursements from an institution of higher education, a federal/state/local government, an academic teaching hospital, a medical center, or a research institute affiliated with an institution of higher education.
To ensure public transparency of investigators' FCOI, investigators who are determined to have an FCOI related to PHS-Funded Research, will have their FCOI posted on the UW FCOI Public Disclosures website. The posting will contain no less than the following information:
All subrecipients proposed must have their own FCOI compliant policy in place and make an assurance in the subaward to this regard. Reminders to the PI and eGC1 contacts regarding this requirement will be sent by OSP at JIT and award stage for PHS-funded projects in which subrecipients are proposed.
An example PHS-compliant FCOI policy for potential adoption by subrecipients that do not yet have their own policy has been provided by the Federal Demonstration Partnership (FDP): http://sites.nationalacademies.org/PGA/fdp/PGA_061001