The UVM Financial Conflict of Interest in Sponsored Research Policy (PDF) implements processes in order to manage situations in which both real and perceived Financial Conflicts of Interests (FCOI) could compromise the objectivity (or perceived objectivity) of research, as required by federal regulations.
In particular, the FCOI Policy requires Investigators to do the following;
- Complete Disclosures. All Investigators must certify or disclose whether or not they hold any Significant Financial Interest (PDF). The UVMClick – FCOI system will automatically remind Investigators when to log in and complete their annual certification/disclosure.
- Complete FCOI Training. FCOI Training is required every 4 years. Navigate to CITI Program, our online source for FCOI Training. FCOI Training reminders will come directly from CITI.
Who needs to submit a Disclosure?
- UVM Investigators must disclose whether or not a Significant Financial Interest (PDF) is held by themselves, their spouses, or their dependent children related to their institutional responsibilities when funded research is proposed, annually thereafter, and make an updated disclosure when any new Significant Financial Interest arises.
- “Investigator” is defined as the Principal Investigator (PI), Project Director (PD) or any other person, regardless of title or position, who is responsible for the design, conduct, or reporting of research proposed to, or funded by, external sponsors, under grants, contracts, cooperative agreements, or other awards for research.
When Do I Submit a Disclosure?
- Annual certification/disclosures are required by all Investigators. UVMClick – FCOI system will automatically remind Investigators when they must log in and complete their annual certification/disclosure.
- The annual certification/disclosure satisfies the requirement that a disclosure is made at time of proposal submission.
- If an annual certification/disclosure is not present at the time of proposal submission, SPA will trigger an event that directs the Investigator to log in and complete disclosure.
Do I need to submit a disclosure if I have nothing to disclose or if I feel like I have no conflict?
If you qualify as an Investigator (see “who needs to submit a disclosure?”), you do need to disclose whether or not you hold a significant financial interest (PDF).
It is not the responsibility of the Investigator to determine whether or not there is a conflict.
It is the responsibility of the research compliance officer, and ultimately the Financial Conflict of Interest Committee, to determine whether there is a conflict with any ongoing research.
As a reminder:
- Significant Financial Interest (PDF) means a financial interest that could directly and significantly, affect the design, conduct, or reporting of externally funded research. Investigators using UVMClick – FCOI will either certify no SFI or disclose SFI.
- Financial Conflict of Interest (FCOI) means a Significant Financial Interest (SFI) that could directly and significantly, affect the design, conduct, or reporting of externally funded research. All disclosed SFI will be reviewed at time of award by our Research Compliance Officer or the FCOI Committee to determine if the disclosed SFI is an FCOI.
Research Certifications At Time of Award Acceptance?
- At time of award acceptance, for those disclosures that indicate a Significant Financial Interest (SFI), SPA will trigger a Research Certification update.
- All research certifications where an SFI exists will be reviewed by our Research Compliance Officer or the FCOI Committee to determine if the SFI is a Financial Conflict of Interest (FCOI).
- Where an FCOI exists, award funds may not be released into PeopleSoft financials until the FCOI is either eliminated or managed with a management plan.
Required FCOI Training
Your training completion date is available here.
- UVM FCOI Policy requires Investigators to complete FCOI training every 4-years.
- CITI is our online source for FCOI Training.
- Login to CITI through the “Log In Through My Institution” portal, selecting the University of Vermont.
- FCOI Training reminders will come directly from CITI.
- Award funds may not be released into PeopleSoft financials until all Investigators are FCOI trained.
Please Note: You will not be able to submit your disclosure if your FCOI training has expired. Once you take the FCOI training, it will take an overnight for your record to transfer over to UVM CLICK, after which point you will be able to submit your disclosure.
UVM FCOI Procedures By Sponsor
Federal Funding Agencies Resources
FCOI Policy vs UVM’ s Conflicts of Commitment Policy
The FCOI Policy is different from UVM’s Conflicts of Interest and Conflicts of Commitment Policy (PDF), which applies to all UVM employees, including staff, whether or not they are engaged in sponsored research. Both disclosures are made under the same disclosure form thru UVM CLICK-COI.