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Financial Conflict of Interest (FCOI)

Promoting objectivity in Research is refined in 42 CFR 50 Subpart F. The Office of Research is responsible for research-related financial conflicts of interest (FCOI). Defined in 42 CFR 50.603, disclosure of significant financial interests means an Investigator’s disclosure of significant financial interests to an Institution. 

What is a Financial Conflict of Interest (FCOI)?

Conflicts of interest in research are present when Significant Financial Interests directly affect, or could appear to affect, the professional judgment of a researcher when designing, conducting, or reporting research. 

Who needs to disclose?

  • All Drexel investigators must disclose at least annually 

  • Non-Drexel investigators must disclose only those Significant Financial Interests (SFI) related to their research

What is considered a SFI?

An SFI is present when any of the following are received by an Investigator or their Immediate Family Member: 

  • Combined income or equity exceeding $5,000 in a publicly traded company 

  • Income exceeding $5,000 or any equity in a privately held company 

  • Income exceeding $5,000 from Intellectual Property not managed by UW 

  • Sponsored/reimbursed travel exceeding $50 

When do I disclose?

At proposal submission, principal investigators submit a FCOI Disclosure Form 1[PDF]. If there is an identified conflict, principal investigators submit FCOI Disclosure Form 2 [PDF]. Should a conflict be reasonably expected to: 

  • Have a direct and significant impact on the design, conduct or reporting of the sponsored project or 

  • Undermine University personnel's obligation to Drexel, the sponsor, research subjects or students.

Why do I need to disclose?

Federal regulations require Drexel to have policies in place to promote objectivity in research for which Public Health Service (PHS) grants or cooperative agreements are sought, 42 CFR Part 50 Subpart F, as well as to address Drexel’s Conflict of Interest and Commitment, Policy Number CPO-2. The Office of Research and Innovation’s COI Policy [DOC] can be viewed here.

COI Committee

The Conflict of Interest Committee reviews the reporting forms to determine whether a significant financial interest is related to the investigator's Drexel research and whether it constitutes an FCOI. Once an FCOI has been identified, the committee recommends a management plan and implementation mechanisms for monitoring to the Executive Vice Provost for Research.