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Faculty Profile: Marc Christensen, Electrical Engineering

SMU Researchers: Financial Conflict of Interest Policy (Deadline for training)

SMU Researchers,

In August 2011, the National Institutes of Health revised the 1995 Financial Conflict of Interest (FCOI) regulation to include language that promotes objectivity in research by establishing “standards” that provide a reasonable expectation that the design, conduct, and reporting of research performed under NIH grants or cooperative agreements will be free from bias resulting from Investigator financial conflicts of interest.

The most significant changes to note in the 2011 revised FCOI policy are listed below:
  • Definition of Significant Financial Interest
  • Extent of Investigators’ disclosure of information to Institutions regarding their Significant Financial Interests
  • Institutions’ management of identified Financial Conflicts of Interest
  • Information reported to the PHS funding component (e.g., NIH)
  • Information made accessible to the public (i.e., Institutional FCOI policy and FCOIs of senior/key personnel) and
  • Investigator training.
In anticipation of the increase in regulatory oversight concerning FCOI, the University created the new 2011 FCOI policy that affects all researchers involved in sponsored projects regardless of funding source.

In order for SMU to be in compliance with the 2011 FCOI regulations, we revised the FCOI disclosure form, created SMU Research Policy 7.7, and are implementing a mandatory FCOI training component. All researchers who submit proposals through the Office of Research Administration (ORA) will be required to complete the new FCOI disclosure form annually in order to submit proposals and spend funds that have been awarded to the institution for your sponsored projects. All researchers are also required to complete the FCOI training.

Due to the short time frame, all researchers who submit proposals through ORA are required to complete the FCOI training through NIH (http://grants.nih.gov/grants/policy/coi/tutorial2011/fcoi.htm) no later than Friday, August 30, 2012.

The NIH training module takes about 15-20 minutes to complete and you can instantly print (and save) your certificate for documentation purposes. The FCOI training must be repeated every for 4 years.

Please make sure that you forward a copy of your certificate to your Grant Specialist so that we can document your file.

We will not be able to submit your proposal or release your award without a copy of the FCOI certificate of completion and the completed FCOI disclosure form.


For those Researchers that have subcontractors and/or consultants included in your sponsored projects, we will include language in those agreements to ensure that the institutions and individuals are compliant with the FCOI regulations. You will be receiving a number of emails and instructions regarding the changes for the FCOI regulations.

At any time, if you have questions or concerns, please call or email me.

Thank you for your time and attention to this matter.

FCOI disclosure form
SMU Research Policy 7.7,