Financial Conflict of Interest and the Promotion of Objectivity in Sponsored Programs

 

The Office of Research and Sponsored Programs has revised (effective 6/10/21) the policy on Financial Conflict of Interest (FCOI) to specifically address federal mandates.  This policy establishes procedures to identify and  manage potential financial conflicts of interest that can arise when an ETSU employee's external relationships and commercial activities result in significant financial interests that may affect the way he/she conducts an ETSU sponsored project or program.

Policy:

 Training:

 Documented completion of FCOI training is required by federal regulations prior to an "Investigator" engaging in federally sponsored research and at least every four years thereafter for as long as he/she is engaged in federally sponsored research.  In this context, an "Investigator" is defined as 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 sponsored research. In addition, ETSU requires completion of FCOI training by an Investigator prior to the submission of his/her first SFI Disclosure Form.  This training requirement may be met by providing evidence of your completion of the CITI online course linked below (please send your certificate to ORSPA, Box 70565 or research@etsu.edu).

Disclosure:

All Key Personnel involved in extramurally-funded research are required to disclose their significant financial interests (and those of their spouse and dependent children) that may be related to their ETSU responsibilities at the following times:

  1. no later than at the time of the application for extramurally funded research;
  2. within 30 days of discovering or acquiring a new Significant Financial Interest; and
  3. at least annually during the period of an award.

In order for ETSU to be compliant with federal regulations, a new or updated disclosure must be submitted by all key personnel for every new proposal submitted, regardless of the time since their last disclosure.  Disclosures should be submitted using the ETSURGe electronic grant management system.

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