NIH Funding: Financial Conflicts of Interest

Investigators applying for, holding, or working on studies must comply with US Public Health Service Financial Conflict of Interest Regulations. PHS regulations apply to all PHS-funded research, including NIH, establishing investigator reporting and training requirements.

Prior to submission of a grant application, on annual renewal and within an update on awarded grant or subgrant, Western’s PIs must ensure:

  • To provide a list of all investigators on the project, including any subrecipient(s);
  • All investigators at Western have signed and submitted a Financial Interest Disclosure Report form;
  • An authorized official of the subrecipient has signed and submitted the Subreceipient External Investigator Institutional Declaration; and
  • Where a Subrecipient External Investigator opts to follow Western’s FCOI policy, they have submitted a Financial Interest Disclosure Report form.

Before submission of a grant application or sub-award, and every four (4) years:

  • Western PIs and all investigators following Western’s FCOI Policy must complete the NIH FCOI tutorial. The NIH Financial Conflict of Interest tutorial was designed by the National Institutes of Health to provide education what constitutes a financial conflict of interest. It provides guidance on the proper policies and practices regarding these issues and is a requirement for anyone involved with an NIH-funded project.

Where subrecipient external investigators who are following their institution’s FCOI Policy are found to have a FCOI, the subrecipient institution must report the FCOI to Western before awarded funds are released, annually, and within 30 days a new FCOI being identified.

Relevant Resources


For post-award administrative support (non-financial), please contact: Xinhong Huang, Research Development Officer (Post-Award).