Disclosure of Investigator Financial Interest

Saint Francis Policy on Disclosure of Investigator Financial Interests

Conflicts of interest arise when private financial interests could potentially affect professional judgment. Having a conflict of interest is not discouraged or even necessarily considered a problem if managed appropriately. Conflicts can, however, become serious problems if these financial interests are not made known to the institution.  

Saint Francis has recently developed policies and procedures to improve our processes for managing investigator’s financial interests and to comply with new regulations relating to financial conflicts of interest (FCOI) of investigators. The final rule can be accessed via the following link (http://grants.nih.gov/grants/policy/coi/fcoi_final_rule.pdf). The new regulations are effective immediately. While the scope of the regulations is only applicable to NIH and PHS-funded research, Saint Francis has adopted these standards for ALL externally funded research. 

Some highlights from the new regulations include: 

  1. Decrease in dollar threshold requiring disclosure 
  2. Increased disclosure requirements for sponsored and reimbursed travel 
  3. Required training for investigators on Saint Francis policy and procedure and the Federal requirements 
  4. Public access to Saint Francis policies and procedures 

In general, the regulation shifts the burden of determining if a FCOI exists from the individual investigator to the institution through its FCOI processes and procedures. 

 Links to Saint Francis Policy, Saint Francis Disclosure Form and Conflict of Interest Training Module are listed below: 

Please contact Jennifer Schneider, Chief Compliance Officer at  jschneider@stfranciscare.org  if you have any questions regarding this new requirement.