COI

Financial Conflict of Interest (FCOI)

Policy and Procedures on Financial Conflict of Interest (FCOI) for Sponsored Programs

CSUDH Presidential Memo 2015-02 requires that each investigator of a sponsored program must disclose significant financial interests, including those of the investigator’s spouse and dependent children, related to their institutional responsibilities. This requirement includes investigators and any other individuals responsible for design, conduct or reporting of research or educational programs.

Financial Disclosure at the Proposal Stage

Financial Conflict of Interest (FCOI) questions must be completed by all investigators as part of the grant proposal clearance process. If a conflict or potential conflict of interest is noted, the investigator may be asked to submit an Addendum describing the nature of the conflict or apparent conflict of interest and proposed strategies for mitigation.

Financial Disclosure When the Award/Contract is Issued

As part of award setup, your pre-award analyst will provide you with the appropriate forms to complete based on your sponsor type. Note that for non-governmental prime agencies, the California Form 700-U is required.

Financial Disclosure Required Throughout Grant/Contract Cycle

• Public Health Service (PHS) projects and select non-PHS agencies using the PHS FCOI regulations (for a complete list, click here) - Annually and within 30 days of discovering or acquiring a new financial conflict of interest. 
• Non-PHS governmental sponsors – Within 30 days of discovering or acquiring a new financial conflict of interest. 
• Non-governmental sponsors – Annually and within 30 days of discovering or acquiring a new financial conflict of interest.

Management of Financial Conflict of Interest

If a potential conflict of interest is disclosed, the Dean of Graduate Studies and Research will review and make a recommendation as to how a management plan should be developed to mitigate potential conflicts of interest.

COI Training Required of all PIs

Beginning July 1, 2022, PIs will need to complete the CITI Program Conflict of Interest training prior to proposal submission. Investigators will automatically receive reminders to be trained every three years once entered into the training system.

For more information about how financial conflicts of interest may affect your grant proposal or award, please contact the Office of Sponsored Research and Programs at srp@ebasd.com.