Financial Conflict of Interest (FCOI)

A significant financial interest that could directly or significantly affect the design, conduct, or reporting of sponsored research.

Institutional Responsibilities

An investigator’s professional responsibilities on behalf of KSU, including but not limited to research, research consultation, teaching, professional practice, and service on institutional committees.

Investigator

Any person, regardless of title or position, who is responsible for the design, conduct, or reporting of research or educational activities funded or proposed for funding by an external sponsor. This includes the principal investigator (PI), co-investigators, and any other key personnel.

Significant Financial Interest (SFI)

A financial interest consisting of one (1) or more of the following interests of the investigator (and those of the investigator's spouse and dependent children) that reasonably appears to be related to the investigator's institutional responsibilities:

• With regard to any publicly traded entity: An SFI exists if the value of any remuneration received from the entity in the twelve (12) months preceding the disclosure and the value of any equity interest in the entity as of the date of disclosure, when aggregated, exceeds $5,000.
• With regard to any non-publicly traded entity: An SFI exists if the value of any remuneration received from the entity in the twelve (12) months preceding the disclosure, when aggregated, exceeds $5,000, or when the investigator holds any equity interest.
• Intellectual property rights and interests (e.g., patents, copyrights), upon receipt of income related to such rights and interests.
• Sponsored or reimbursed travel: For PHS-funded investigators, the occurrence of any reimbursed or sponsored travel related to their institutional responsibilities.

A significant financial interest does not include: salary, royalties, or other remuneration paid by KSU; income from investment vehicles, such as mutual funds, over which the investigator does not exercise control; income from seminars, lectures, or teaching engagements sponsored by a U.S. federal, state, or local government agency or an institution of higher education; or income from service on advisory committees or review panels for a U.S. federal, state, or local government agency or an institution of higher education.

PROCESS:

Disclosure of Significant Financial Interests

All investigators are required to complete and submit an SFI disclosure form to the Office of Research & Innovation (ORI):

• At the time of proposal submission to any external sponsor.
• Annually, for the duration of a sponsored award.
• Within thirty (30) days of discovering or acquiring a new SFI.

This disclosure must include all SFIs related to the investigator's institutional responsibilities.

Review and Management of Conflicts