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August 24, 2012

Purdue implements new NIH financial conflict of interest requirements

New financial conflict of interest disclosure and education requirements are in effect for all "investigators" on proposals submitted to the National Institutes of Health (NIH) and other Public Health Service (PHS) sponsors beginning today (Aug. 24). These requirements are the result of a new regulation announced in August 2011.

For proposals submitted to NIH or other PHS sponsors on or after Aug. 24, 2012, project investigators must:

* Disclose all significant financial interests (SFI) related to their university responsibilities before the proposal is submitted to the NIH/PHS sponsor.

* Complete training related to financial conflicts of interest (FCOI) prior to beginning work on an NIH/PHS-funded project.

* Update their SFI disclosure within 30 days of acquiring a new Significant Financial Interest, throughout the period of proposal review or the life of a funded project.

An "investigator" is the project director (PD)/principal investigator (PI) and any other person, regardless of title or position, who is responsible for the design, conduct, or reporting of research funded by the NIH/PHS, or proposed for such funding, including persons who are subgrantees, contractors, consortium participants, collaborators, or consultants. Depending on their responsibilities for the project, postdoctoral scholars, graduate students, and other project staff may be "investigators."

To comply with these new requirements, when a faculty member begins to work with Sponsored Program Services (SPS) on a proposal, the PI will be asked to identify all investigators for the project. Each investigator will receive an email request to complete a Financial Interest Statement (FIS) via a secure website and a reminder of the FCOI education requirement. If a manageable FCOI is identified, a management plan will be developed and implemented.

To satisfy the FCOI education requirement, each investigator should follow instructions provided on the OVPR FCOI website at www.purdue.edu/research/vpr/rschadmin/coi/index.php to complete a brief tutorial. When the project is awarded by the NIH/PHS sponsor, the PI will be asked to verify the list of project investigators. Each investigator will be responsible for updating their FIS via the secure website within 30 days of acquiring a new SFI and at least annually through the life of the sponsored project.

A link to Purdue's Policy on Individual Financial Conflict of Interest (Policy III.B.2) and additional information on Purdue's implementation of the NIH/PHS financial conflict of interest requirements are available on the OVPR's Conflict of Interest website at www.purdue.edu/research/vpr/rschadmin/coi/index.php.  Questions may be directed to Voichita Dadarlat (voichi@purdue.edu) or Peter Dunn (pedunn@purdue.edu).