Significant Financial Interest (SFI) and Financial Conflict of Interest (FCOI): Procedures and Guidance

Step-by-Step Guide for Updating Your SFI Disclosure

Overview

To maintain a research environment that promotes the highest standards of integrity and ethics, Texas State University has established UPPS NO. 02.02.07, Research Conflicts of Interest in Research and Sponsored Program Activities. Its purpose is to promote objectivity in research and to ensure that all research and sponsored program activity conducted by university researchers is free from bias resulting from conflicts of interest (COI). It is paramount that faculty and staff members identify, disclose, and appropriately manage or eliminate situations in which their personal or familial interests might otherwise compromise or appear to compromise their objectivity as teachers, researchers, or administrators. An effective conflict of interest policy helps both to safeguard the work and reputations of University faculty and staff members and to ensure the University’s compliance with federal and other regulatory requirements relating to conflicts of interest.

UPPS No. 02.02.07 requires all researchers to file disclosure forms annually and to update their disclosures when circumstances change. All “Investigators” must update their forms within 30 days of discovering or acquiring a new financial interest related to their university responsibilities

SFI Disclosure Requirements

In order to submit a proposal, initiate a contract, or open a grant account, you must have a current disclosure of Significant Financial Interests (SFI) on file. Texas State researchers are required to submit an SFI Disclosure at least once annually.

Key points about your SFI Disclosure:

• You are being asked to disclose all your significant financial interests rather than just financial conflicts of interests related to your current or potential sponsor.
• Significant financial interests do not necessarily indicate the existence of financial conflicts of interest.
• Annual SFI Disclosures are required from all researchers, regardless of funding source or funding status.

Additional Requirements for NIH and other Public Health Service (PHS) Awards

If you are receiving an award from NIH or one of the other PHS agencies, you will need to complete CITI’s online “Conflicts of Interest” training module. Please contact RIC when you receive a notice of award to ensure NIH & PHS compliance requirements are fulfilled on time.

Texas State subscribes to the nationally recognized Conflicts of Interest training program offered by CITI (Collaborative Institutional Training Initiative). Curriculum content is provided by well-known experts and is updated regularly. The CITI program is available online 24 hours a day, and applicants can save their progress, log in and out of modules, and finish courses at their own pace.

The curriculum consists of modules containing lessons and short multiple-choice quizzes. Texas State subscribes to a number of courses used for various other training requirements through CITI. Because of this, you will be presented with a series of questions or options to enable you to enroll in the Learner Group appropriate to your research needs. Go to the CITI website and click “LOG IN THROUGH MY INSTITUTION” to access the Conflict of Interest training modules.

SFI disclosures are reviewed at both the annual submission period and (if an SFI is disclosed) time of the grant award. If it is determined that an FCOI exists, the Conflict of Interest (COI) Official will assemble an COI Review Committee to develop a set of processes and conditions (Management Plan) to assure that the design, conduct or reporting of research is free from bias and the appearance of bias.

The COI Review Committee will typically include the investigator, an administrator from the investigator's department of college, and RIC Director.