A presentation this morning by staff from Emory University was very interesting, as it reviewed the history leading up to the current PHS financial conflict of interest regulation and discussed the new regulation requirements in light of Emory’s experience. Emory had a DOJ finding on a program project grant in 2008 for financial conflict of interest and had special reporting requirements? Other institutions have followed. Requirements of the new regulation include increase reporting requirements for all investigators on all PHS grants who have asignificant financial interest related to their institutional commitment, and monitoring of subcontractor FCOIs.
- Travel on sponsored projects
- Remuneration or interest in a public company of $5000 or more
- Any level of ownership in a private company
The prior regulations used to allow the investigator to determine what relationships were related to his or her research. This regulation requires all disclosures be made and the institution decides what is related.
All new investigators added to an award must have FCOI reviews, and all FCOI declarations are required before a proposal is submitted.