Financial Conflict of Interest
Western Washington University promotes objectivity in research by requiring that investigators disclose situations in which financial or other personal considerations may compromise, or have the appearance of compromising, the design, conduct, and reporting of the research at the time of the application for funding.
Those engaged in NIH funded projects are required to complete a financial conflict of interest training. Contact email@example.com for more information.
Who must disclose a Financial Conflict of Interest?
Anyone with external funding from any source including PIs, faculty and staff, graduate students, undergraduate students, and the spouse or dependent children of any of the above.
How is Financial Conflict of Interest defined?
Definitions are provided within the disclosure documents and vary depending on the funder.
Anyone with an NIH grant should use the <<link coming soon>> form.
All other externally funded projects, including those funded by NSF, should use the <<link coming soon>> form.
When does the disclosure need to be made?
WWU researchers are required to indicate whether they have a financial conflict of interest, or a situation that could be perceived as a conflict of interest, before they submit an application.
The required <<Proposal Routing Form>> provides an opportunity for researchers to indicate that they have no conflict of interest prior to submitting their proposal. Use the <<Reporting Financial Conflict of Interest Form link coming soon>> to disclose a possible conflict of interest in research funded by NSF, PHS (including NIH), and agencies that have adopted PHS regulations. For all other externally funded project use the <<link coming soon>> document to disclose financial conflicts of interest.
Subsequent to an initial disclosure, investigators must submit updates annually by January 15. If the Investigator acquires a significant financial interest during the course of the year between annual disclosures, the Investigator must report it to Director of Research and Sponsored Programs within 30 calendar days.
Who reviews my disclosure?
Conflict Review Committee reviews disclosures of potential conflicts. The committee consists of the Vice Provost for Research, Assistant Attorney General, Risk Manager, and the Director of the Office of Research and Sponsored Programs.
What happens when I disclose a Financial Conflict of Interest?
The Conflict Review Committee will develop a plan to address a financial conflict of interest, which can include reducing, managing, or eliminating the financial conflict of interest, to ensure, to the extent possible, that the design, conduct, and reporting of research will be free from bias. The management plan may also include a retrospective review and mitigation report, if necessary.
Where can I find the relevant FCOI Policies and Procedures?
- POL-U4520.06 Reporting Financial Conflict of Interest by Public Health Services
- POL-U5400.20 Financial Disclosure Policy For Externally Funded Projects
- eCFR :: 42 CFR Part 50 Subpart F -- Promoting Objectivity in Research
- PAPPG Chapter IX