Institutions to Submit FCOI Policy Electronically in eRA Commons, Effective November 12, 2020


NIH requires institutions to maintain an up-to-date, written, and enforced policy to identify and manage Investigator Financial Conflicts of Interest (FCOI) and to post the policy on their publicly accessible website. Starting November 12, 2020, NIH recipients will be required to submit their publicly assessible FCOI policy to NIH via the eRA Commons Institution Profile (IPF) Module.

This new feature will apply to all NIH applicants and/or recipients, with the exception of Phase I Small Business Innovative Research (SBIR) or Small Business Technology Transfer (STTR) applicants and/or recipients. (See NIH GPS Section 4.1.10 Financial Conflict of Interest for more information). This new feature does not change the current requirements.

A PDF of the FCOI policy must be uploaded to the IPF by the institutional signing official (SO) under a new tab labeled “Policy Documents.”

Screenshot of the top of the IPF, highlighting the new Policy Documents tab
Screenshot of the top of the eRA Commons Institution Profile (IPF), highlighting the new Policy Documents tab

The information is provided on an institutional level as part of an institution’s IPF, rather than on a grant-specific level, so it is not necessary to submit the FCOI policy with each grant application.

While the requirement goes into effect in November, NIH recognizes that recipients will need time to modify their internal systems in order to comply. Therefore, applicants and recipients have until December 1, 2020 to comply with this requirement. The new feature within the IPF screen becomes available on November 12, 2020.

Note that noncompliance with this requirement as of December 1, 2020 may cause NIH to delay the issuance of awards, impose specific award conditions or take other enforcement actions.

NIH will review the submitted FCOI policies to ensure compliance.


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