Financial Conflict of Interest: Who must disclose?

Financial conflicts of interest (FCOI) requirements apply to all “investigators” involved in funded sponsored research activities.

Frequently Asked Questions

State and Federal regulations require TAMU-CC to have policies in place to promote objectivity in research, for which PHS Funding is sought (42 CFR Part 50 Subpart F), and to address State laws prohibiting state employees from having an interest that is in conflict with their official duties.

The purpose of this regulation is to protect the credibility and integrity of system researchers and staff, as well as member universities and agencies themselves, so the public's trust and confidence in their research activities are maintained.

Any individual acting as a “project director, principal investigator or any other person, regardless of title or position, who is responsible for the design, conduct, or reporting of research” is an investigator and must satisfy the disclosure requirements.

Investigators include those who are “responsible for the design, conduct, or reporting of research” (e.g., principal investigator, co-principal investigator, project director, students who receive compensation in the form of scholarship, salary, or tuition reimbursement). Any University employee, regardless of title or position, who has the ability to make independent decisions related to the design, conduct, or reporting of University research must satisfy the disclosure requirements as well. This does not include individuals who perform only incidental or isolated tasks related to a University research project.

In nearly all situations when an individual is listed as senior or key personnel on a proposal or award, they are considered an investigator for purposes of submitting a financial disclosure statement.

Yes. COI training and disclosure requirements apply to all individuals responsible for the design, conduct, or reporting of research, regardless of the funding source or field of study.
Yes, if they meet the definition of “investigator” above. Since title and position are not indications of who is an "investigator," it is possible for students and post-docs to meet this definition.

A “Covered Family Member” includes a:

  1. Spouse;
  2. Dependent child or stepchild or other dependent, for purposes of determining federal income tax liability during the period covered by the disclosure statement; or a
  3. Related or non-related, unmarried adult who resides in the same household as the covered individual and with whom the covered individual is financially interdependent as evidenced, for example, by the maintenance of a joint bank account, mortgage, or investments.

If the covered individual is in doubt about whether an individual is a covered family member, the covered individual should resolve the doubt in favor of disclosure.