Application of Public Health System Conflict of Interest
Policy to Non-Federal Sponsors
non-federal granting agencies, including the American Heart Association,
are now following the Public Health System (PHS) Financial Conflict of Interest
(FCOI) policy. Accordingly, Grants and Contracts will follow the same
procedure which governs PHS with respect to Conflict of Interest
disclosures. This means that if an agency follows the PHS FCOI policy,
all key personnel will need to have a COI disclosure on file with the
Office of Regulatory Compliance before the grant may be submitted to the
information concerning Conflict of Interest is Available on Grants and
Contracts website and Office of Regulatory Compliance-Conflict of Interest
Please contact Grants and Contracts if you have
There are new PHS regulations relating to conflict of interest, please note that as of 8/24/12 the following changes will take effect:
You must have updated or submitted a new COI disclosure after 8/24/12 to submit a grant to NIH;
The definition of investigator has been broadened to include key personnel who may potentially bias the design, conduct or analysis of a study – so can include consultants, PRAs and statisticians depending on the scope of work outlined in the grant
You must disclose any financial remuneration from professional organizations as well as financial remuneration provided by a commercial sponsor;
You must disclose any travel remuneration from professional organizations or a commercial sponsor;
Institutions named as sub-recipients must certify that they will follow PHS regulations or named investigators will need to complete a disclosure with UC Denver I Anschutz Medical Campus
If an investigator named on an award declares a financial interest that meets the definition of a significant financial interest then no money can be drawn on a PHS award until the Conflict of Interest Office determines whether or not the significant financial interest potentially could conflict with the project. If the latter is determined then a management plan developed, signed by the investigator and submitted to NIH before funds can be released.
The Conflict of Interest Office must make approved management plans available to a member of the public within 5 days of the request for a plan;
There is a mandatory training requirement – in the new disclosure form there will be a training section and electronic quiz to determine understanding of the new requirements.
UC Denver encourages and supports outside interactions of its faculty and student employees with federal, state, and local governments, and with business and industry as important parts of their research, education, and public service activities. In limited cases, similar opportunities are encouraged for University staff members as well.
Since outside interactions also carry with them an increased potential for conflict of interest and/or commitment, either actual or perceived, UC Denver should have adequate procedures for identifying potential conflicts through annual disclosure, and ensure rigorous and consistent review of such disclosures. A disclosure in and of itself is not suggestive of any impropriety; rather, it is customary and usual and benefits both the individual and the University. Indeed, full disclosure of relevant information and the establishment of a public record are in the best interest of both the UC Denver and its faculty and student employees.