Financial Conflict of Interest

The National Science Foundation (NSF) and Public Health Service (PHS) have issued regulations on Financial Conflict of Interest (FCOI) as related to research funded by these agencies. Skidmore College recognizes that faculty and staff engage in many relationships with outside entities, some of which might create an FCOI, or the appearance of a conflict of interest. Skidmore College, therefore, recognizes its obligation to ensure that research and other scholarly activities are carried out under the highest standards of integrity and ethical conduct.

Skidmore College is required to create and maintain a written and enforced policy stating the procedures for implementing the FCOI regulations and to inform each investigator of the regulations, of the College's FCOI policy, and of the investigator's disclosure and training responsibilities under the regulations and the policy.

Skidmore College's FCOI policy establishes requirements and guidelines for disclosures of financial interests and professional relationships related to research projects, certifications of policy compliance, and processes that ensure compliance. The policy requires that principal investigators (PIs) and all other key personnel who have or share responsibility for the design, conduct, or reporting of NSF or PHS sponsored projects must report their personal financial interests in any organization(s) that, to the best of the Investigator's knowledge, may be related to their institutional responsibilities. (Key Personnel include PIs and any other individuals that are responsible for the design, conduct, or reporting of research.) 

This policy applies to all PHS research activities with an award issue date of August 24, 2012 or later, and to proposals for research activities submitted to PHS on or after August 24, 2012. (Please note as of 2022: The Department of Energy (DOE) Interim COI Policy is largely aligned with PHS requirements and will be used interchangeably throughout the policy requirements.)

This policy also applies to research or educational activities funded or proposed for funding by the National Science Foundation.

To the extent that other funding agencies or organizations (whether governmental or private) have adopted financial conflict of interest policies and procedures, Skidmore College will comply with such policies and procedures when applicable.

FCOI Disclosure Requirement

PIs and other key personnel are required to disclose to Skidmore College all of their Significant Financial Interests (and those of the Investigator’s spouse and dependent children) that reasonably appear to be related to their institutional responsibilities:

1. at the time of application for NSF/PHS/DOE-funded research;
2. no later than thirty days from the date of discovering or acquiring (e.g., through purchase, marriage, or inheritance) a new Significant Financial Interest; and
3. at least annually during the period of award.

One of the following appropriate Financial Conflict of Interest (FCOI) forms must be completed by all PIs and other key personnel. There are two forms that are used depending on the source of funding:

• PHS / NIH FCOI Disclosure Form (this form will be used for DOE as well)
• NSF FCOI Disclosure Form

FCOI Training Requirement (applicable for those funded by PHS and DOE) 

PIs and other key personnel receiving PHS and DOE funding, including key personnel on subawards, will need to complete initial FCOI training and then every four years thereafter. PIs must also notify the Office of Sponsored Research if there are others working on any PHS and DOE funded research projects that, regardless of title or position, are responsible for the design, conduct or reporting of the research. All such personnel will also be required to complete the training.

Skidmore College, in conjunction with CITI, has developed a web-based training module in order to comply with the FCOI training requirement.

PIs and other key personnel, including key personnel on subawards, must complete FCOI training:

1. before engaging in research funded by PHS or DOE;
2. at least every four years.

PIs and other key personnel must also complete FCOI training immediately under the following circumstances:

1. Skidmore College’s FCOI policies change in a manner that affects investigator requirements;
2. An investigator is new to Skidmore College; and
3. Skidmore College finds an investigator to be noncompliant with Skidmore College’s FCOI policy or management plan.

Log in to CITI to access the Conflict of Interest course to complete the training module. Select the Conflict of Interest course via Question 9 in Skidmore's list of course enrollment questions. 

Verification of FCOI Training

PIs are responsible for ensuring that all key personnel on a project have completed training prior to engaging in the research. Skidmore College is responsible for verifying that investigators supported by PHS and DOE have received FCOI training. Successful completion of training will be tracked for all PIs and other key personnel receiving PHS and DOE funding.