FCOI Initial Disclosure

Financial conflict of interest disclosures must be submitted and processed in the iRIS electronic compliance platform. Sponsored projects that do not include animals, humans, biohazardous material, or any other regulatory compliance concern may still include a conflict of interest. For this reason, the PI and key personnel of all research and sponsored projects are required to complete a financial conflict of interest disclosure and update this disclosure on an annual basis or any time that a new significant financial interest is acquired.

• Key personnel of a project that was submitted for IACUC, IBC, or IRB review, will automatically receive a request to complete COI Disclosure form in the iRIS electronic compliance platform. The form will be added as an item in the Tasks panel of their iRIS account.

• Key personnel of sponsored projects that do not involve an IACUC, IBC, IRB, or other regulatory compliance component must also complete a Conflict of Interest Disclosure form in the iRIS electronic compliance platform. However, the process to access the form in these cases is different. The Supplemental FCOI form must be completed and submitted. Once this form is reviewed and approved by the FCOI Committee, a letter of approval will be generated and can be included in the sponsored project submission. 

FCOI Review Process

1. Key personnel complete the FCOI disclosure form in the iRIS platform and submit it for review. 

2. The ORRC reviews the disclosure form and assesses any conflict matches that are found. If a Significant Fianacial Interest (SFI) is determined, the COIRC will be convened to review the SFI and develop a management plan to resolve the conflict.

3. The PI will be notified of the final determination by the ORRC or COIRC. If applicable, the management plan and any further instructions, conditions, or restrictions will be communicated to the PI. Conditions or restrictions that may be imposed on a PI or project to manage or eliminate financial conflicts of interest may include, but are not limited to one or more of the following:

   • Public disclosure of significant financial interests . 

   • Monitoring of research by independent reviewers. 

   • Modification of the research plan. 

   • Disqualification from participation in all or a portion of the research. 

   • Divestiture of financial interests. 

   • Severance of relationships that create actual or potential conflicts. 

   • For research projects involving human subjects, disclose financial conflict of interest directly to participants. 

For sponsored projects that do not include a regulatory compliance component, the PI should include the determination notification from the review in iRIS in their sponsored project application as evidence of FCOI disclosure.