The NIH (and PHS) regulation requires that Investigators[i] take responsibility for the following: 

1) Completing Compulsory FCOI training

  • The online NIH FCOI Training tutorial must be completed before submitting an application or engaging in research relating to any NIH grant
  • The certificate at the end of the tutorial must be printed off, and kept on file for audit purposes
  • The training must be repeated at least every 4 years

      In addition you are required to repeat the training when:

  • NIH FCOI policy changes affect requirements.
  • You are new to the University.
  • When an academic department/school/faculty finds that you have been non-compliant with the University’s FCOI procedure on NIH –funded projects 

2) Disclosing Significant Financial Interests (SFI)

The timeframe for SFI disclosure is:

  • Before the time of application for the NIH funded research: this must be done in addition to the Annual Staff Declaration on a separate Declaration Form
  • At least annually during the period of the award
  • Within 30 days of discovering or acquiring a new SFI
  • Failure to disclose within the above timescales will result in additional reporting obligations to NIH
  • Complete the relevant FCOI declarations on the KRISTAL Risk Review dashboard that supports financial approval.
  • Where a Significant Financial Interest has been declared, immedietaley contact the Designated Official and your Faculty Research anhd Innovation Office for consideration of the  SFI.

3) Adherence to an agreed Managment plan (in the case that one is required following an identified FCOI)

[i] 'Investigator’ as project director or principal investigator and any other person, regardless of title or position, who is responsible for the design, conduct, or reporting of research funded by the NIH, or proposed for such funding, which may include, for example, collaborators or consultants.