Electronic Financial Conflict of Interest Reporting Required as of July 2009

Use of the new electronic Research Administration (eRA) Commons Financial Conflict of Interest (FCOI) reporting module will be required as of July 1, 2009. The FCOI module allows institutions to initiate and prepare FCOI reports electronically, to submit those reports, to search and view FCOI reports previously submitted through the Commons, to edit or rescind reports, and to create and access a history of institutional actions.

Prior to spending funds under an award, the regulations require that the institution report the existence of any conflicting interests and assure the NIH that the interest has been managed, reduced, or eliminated. The nature of the interest or other details about the interest are not reportable. For any interest that the institution identifies as conflicting after the institution’s initial report, a subsequent report must be made and the interest managed, reduced, or eliminated–at least on an interim basis–within 60 days of identification of the FCOI. FCOI reports to NIH are mandated by Federal regulations at 42 CFR Part 50 Subpart F, Responsibility of Applicants for Promoting Objectivity in Research for which PHS Funding is Sought.