Financial Conflict of Interest (FCOI)
The Financial Conflict of Interest Policy, Grants Information Memorandum (GIM) 10, establishes guidelines for disclosure of Significant Financial Interests and management of Financial Conflicts of Interests in Sponsored Research at the University. The information accessible through this page provides details of the relevant policies, procedures, and systems.
SFI Review Process
What is a Financial Conflict of Interest?
Conflicts of interest in research are present when Significant Financial Interests directly affect, or could appear to affect, the professional judgment of a researcher when designing, conducting, or reporting research.
Who needs to disclose?
- All PHS Investigators must disclose at least annually
- Non-PHS Investigators must disclose only those Significant Financial Interests related to their research
What is considered a SFI?
An SFI is present when any of the following are received by an Investigator or their Immediate Family Member:
- Combined compensation* and equity exceeding $5,000 in a publicly traded company
- Compensation* exceeding $5,000 or any equity in a privately held company
- Compensation* exceeding $5,000 from Intellectual Property not managed by the UW
* Sponsored/Reimbursed travel is a form of compensation when associated with a performed service
When do I disclose?
New or increased SFI need to be disclosed:
- Within thirty (30) days of acquisition
- Within thirty (30) days of starting a new, or joining an ongoing, research project
- At least annually by PHS Investigators
Why do I need to disclose?
State and Federal regulations require the University of Washington to have policies in place to promote objectivity in research for which PHS Funding is sought (42 CFR Part 50 Subpart F), as well as to address State laws prohibiting state employees from having an interest that is in conflict with their official duties (42.52 RCW).
How do I disclose?
Using the Financial Interest Disclosure System (FIDS) – Overview and Navigation
Collaborations and Reporting PHS FCOI
For collaborating institutions reporting FCOI or requesting updates regarding FCOIs identified in PHS-Sponsored Research at the UW please contact us at firstname.lastname@example.org.
- I’m a PHS-Investigator and I received $5,000 in compensation for serving on the Scientific Advisory Board of a local biotechnology company, I anticipate receiving an additional $2,000 for these services in the next few months—am I required to disclose this compensation?
- Yes, compensation exceeding $5,000 received, or anticipated to be received, within a twelve (12) month period requires disclosure under GIM 10.
- I’m a Non-PHS Investigator and I received $6,000 in compensation for serving on an Engineering Advisory Board for an Industrial Engineering firm—am I required to disclose this compensation?
- If you advised on products or services you are evaluating in the course of your University research, or you believe the work you are doing on the Advisory Board is related to any of your University research, you must disclose this compensation and be put on a Conflict Management Plan to mitigate any concerns which may arise under Washington State Ethics laws.
- I am working with CoMotion to patent technology that I developed in my University laboratory. Do I need to disclose this as an Intellectual Property interest? What if I’m on the Board of Directors for a Company that wishes to license my technology?
- No. Intellectual Property, and any associated royalties or payments that are managed by the UW are considered to fall within your University responsibilities and compensation. Disclosures of Significant Financial Interests in private companies should be submitted by PHS-Investigators regardless of the entities’ interest in University technology. All Innovators with SFI in an entity licensing technology for which they are a contributor will be issued a Conflict Management Plan—CoMotion and the Office of Research work together closely at time of Option or License to ensure compliance with applicable policies.
- I am receiving money from Industry, both for my salary and for expenses to conduct research related to one of their products or services, should I disclose this as SFI?
- No. Any sponsored-research managed by the University, that is—it was routed through an eGC1 and negotiated by the Office of Sponsored Programs—is considered to fall within the scope of your University responsibilities and compensation. If the entity sponsoring University research is also paying you directly for other services, that compensation may require disclosure as outlined by GIM 10.
- Non-PHS Investigators are required to disclose those Significant Financial Interests they deem to be related to their sponsored research. Because the Investigator has already made a determination of relatedness, most SFIs disclosed for non-PHS research will result in a Conflict Management Plan being issued.
- All Technology Transfer transactions for which an Innovator has a Significant Financial Interest in the entity licensing University technology require Conflict Management Plans.
- Financial Conflicts of Interest identified in PHS-Sponsored Research must be made available to the public, and so are posted to a University of Washington webpage. These FCOI are also reported annually to the sponsoring agency via eRA Commons.
I submitted and received approval for outside work via the Request for Approval of Outside Professional Work for Compensation (Form 1460) process, do I also need to report the compensation as a Significant Financial Interest in FIDS?
Yes, if the compensation meets the thresholds defined in GIM 10 it will require disclosure in FIDS.
- Who is an Investigator?
- An “Investigator” includes the Principal Investigator (PI) and any other person, regardless of title or position, that is responsible for the design, conduct, or reporting of research.
- Do I need to submit disclosures of my Significant Financial Interests?
- All Investigators should be submitting disclosures of Significant Financial Interests. For Non-PHS-Funded Investigators, these disclosures need only occur when the Investigator determines the SFI is related to the research. For PHS-Funded Research, all Investigators—that is, anyone contributing to the design, conduct, or reporting of the research—are required to disclose SFI or affirm they have no SFI. This includes faculty, postdoctoral fellows, graduate students, undergraduate students, and staff.
- Can my Department Administrator or Assistant submit my disclosures for me?
- No. All Investigators are required to use their own UW NetID to log in to FIDS and complete their disclosures.
- Do I need to access FIDS?
- All you need is your UW NetID and your password.
- Do I need to include any detail about services I’ve provided which resulted in this external compensation?
- Yes, including a concise description of outside work activities, and/or a description of the company’s line of business or the line of business for which services were provided, will enable the quickest review of SFI for FCOI and will reduce likelihood the Office of Research will need to contact you to collect more detail about the disclosed SFI.
- Do I have to disclose SFI?
- Non-PHS-Investigators must disclose related SFI at time of eGC1 submission to OSP. PHS-Funded Investigators are required to disclose prior to application, within thirty (30) days of joining a research project, and at least annually.
- Are my disclosures reviewed?
- In most cases, SFI are not reviewed until and unless a project is awarded. Exceptions include: No Cost Extensions, Advance Budget Requests, Technology Transfer Agreements, IRB-only disclosures.
- Do I certify to the sponsor that I’ve completed the required training or submitted a disclosure?
- The Office of Sponsored Programs handles all certifications, both for individuals and the institution. If your sponsor is requiring additional certifications, such as assurance of no institutional conflict, contact the Office of Research for assistance.
- Do I request SFI review for an IRB activity that does not have a corresponding eGC1?
- Contact the Office of Research for assistance.