Financial Conflicts of Interest FAQs

Yes. Investigators either participating in or proposed to participate a PHS-funded project must complete a mandatory training. Please view the Training link at left for more information.

Details for what constitutes an SFI are available on the disclosure form and include both remuneration (e.g., consulting fees, honoraria, paid authorship), equity interests (e.g., stock, stock options or other ownership interests), intellectual property rights (e.g., patents and copyrights) or sponsored/reimbursed travel received from an external entity.

The largest PHS entity, with many sub-entities, is the National Institutes of Health (NIH).  The following additional entities also fall under the Public Health Service as of February 2014:

• Office of Global Affairs (OG)
• Office of the Assistant Secretary for Health (OASH)
• Office of the Assistant Secretary for Preparedness and Response (ASPR)
• Agency for Health Care Research & Quality (AHRQ)
• Agency for Toxic Substances and Disease Registry (ATSDR)
• Centers for Disease Control and Prevention (CDC)
• Food and Drug Administration (FDA)
• Health Resources and Services Administration (HRSA)
• Indian Health Service (IHS)
• National Institutes of Health (NIH)
• Substance Abuse and Mental Health Services Administration (SAMHSA)

Additionally, many other entities have elected to use the PHS FCOI regulations. A full and updated list is available through the Federal Demonstration Partnership institutional clearinghouse.

The National Institutes of Health has published an extensive list of FAQs.

To talk to a university representative about FCOI, call 208-885-6162 or email uifcoi@uidaho.edu.

Principal investigators and all Co-PIs on a Public Health Service or National Science Foundation funded project must fill out a disclosure form. Additionally, anyone that the PI identifies as falling under the category of "investigator" must fill out the form. The term investigator means anyone participating in the project who assumes independent responsibility in the project's design, conduct, analysis or reporting of research.

• Investigators on an existing PHS-funded project must disclose through the OSP Portal annually, whether or not there are any changes to report. The form should include any previously reported significant financial interests (SFI).
• Investigators on a proposed PHS-funded project must submit a disclosure form prior to submission of the proposal to the sponsor. Note that this includes not only UI investigators, but also subrecipient and/or collaborator investigators.
• Investigators who discover or acquire a new SFI must submit a new disclosure form within 30 days of discovery or acquisition.

If, after reading the questions on the disclosure form, you are unsure whether or not you should report an outside activity/financial interest, then you should err on the side of caution and disclose the information.

If an issue should arise in the future, having reported the activity/relationship offers some protection to you and the university in terms of how the matter is perceived by others. Failure to report an activity/relationship may be misinterpreted as a desire to hide the activity.

Regulation and policy require the university to have disclosure forms on file for all investigators, whether or not they have a significant financial interest to report.

Investigators must disclose travel in certain cases, as follows:

If you are participating in research funded by PHS entities:

According to PHS regulations, the occurrence of any travel paid by a third party related to the investigator's institutional responsibilities is considered a significant financial interest and is disclosable. 

Third party paid travel means:

• Third party directly pays in whole or in part for travel on your behalf
• You pay for travel and third party reimburses you in whole or in part
• University of Idaho pays in whole or in part for travel and the third party reimburses UI

PHS regulations require you to disclose travel paid by:

• External professional organizations and societies
• Academic journals and publishing companies
• Any travel reimbursed or sponsored by a foreign institution of higher education or the government of another country.

PHS regulations consider travel paid by the following types of entities to be non-disclosable:

• Paid by UI or funded by a sponsored award to UI
• U.S. federal, state or local government agencies
• U.S. institutions of higher education or U.S. research institutes
• U.S. academic teaching hospitals or U.S. medical centers that are affiliated with U.S. institutions of higher education.

If you are participating in research funded by NSF:

You are not required to disclose travel expenses.

You are required to disclose travel paid by:

• External professional organizations and societies
• Academic journals and publishing companies
• Any travel reimbursed or sponsored by a foreign institution of higher education or the government of another country.

At a minimum you should disclose the following information on your travel disclosure:

• The purpose of the trip
• The identity of the sponsor/organizer
• The destination
• The duration

Additional information may be requested as needed in order to determine whether the travel constitutes a Financial Conflict of Interest with the PHS-funded research.