All investigators (see below for definition) participating in Public Health Service (PHS)-funded research are required to update their conflict of interest disclosure each time they submit a new PHS proposal. In order for the institution to conduct the required Financial Conflict of Interest (FCOI) review, all investigators listed on a PHS proposal must ensure that their conflict of interest disclosure is updated at the time of each new PHS proposal submission, as each proposal must be reviewed in the context of the specific research being proposed.
Under UMB's Policy and Procedures on Financial Conflict of Interest to Promote Objectivity in Public Health Service-Funded Research, each investigator who is planning to participate in, or who is participating in, PHS-funded research shall disclose any significant financial interest (and/or of the investigator’s spouse and dependent children) to the COI Officer if it reasonably appears that a significant financial interest is related to the investigator’s institutional responsibilities.
Prior to UMB's expenditure of any funds under a PHS-funded research project, the COI Officer shall in his reasonable discretion, determine whether any significant financial interest is related to PHS-funded research. If the significant financial interest is related to PHS-funded research, the COI Officer, in his reasonable discretion, shall then determine whether a FCOI exists. A FCOI exists if the significant financial interest could directly and significantly affect the design, conduct, or reporting of PHS-funded research.
Investigator: This term refers to: (1) The project director or principal investigator of any PHS-funded research; and (2) any other person, regardless of title or position, who is responsible for the design, conduct, or reporting of PHS-funded research, or proposed for such funding, which may include, for example, collaborators or consultants.