New requirements for disclosure of financial interests, training, and management and reporting of conflicts of interest associated with research projects funded by NIH and other Public Health Service (PHS) agencies became effective August 24, 2012 and for the Department of Energy (effective June 15, 2022).
List of PHS Agencies to which this policy applies:
- Agency for Healthcare Research and Quality (AHRQ)
- Agency for Toxic Substances and Disease Registry (ATSDR)
- Centers for Disease Control and Prevention (CDC)
- Food and Drug Administration (FDA)
- Health Resources and Services Administration (HRSA)
- Indian Health Service (IHS)
- National Institutes of Health (NIH)
- Office of the Secretary
- Substance Abuse and Mental Health Services Administration (SAMHSA)
The University of Tulsa Financial Conflict of Interest Policy for Research Conducted Under the Public Health Service and the Department of Energy can be found here. All faculty who meet the definition of “Investigator” must complete the requisite disclosures and training requirements.
“Investigators” are the Project director or Principal Investigator and any other individual, regardless of title or position, that the Principal Investigator identifies as independently responsible for the purpose, design, conduct or reporting of research which may include collaborators or consultants. This includes, but is not limited to, Senior/Key Personnel named in a proposal.
A summary of Investigator requirements are below:
The Principal Investigator (PI) submitting a new request for funding must complete the Principal Investigator Summary of Investigators Related to Applications Submitted to and Funded by PHS/DOE. When completing this form, the PI will designate the individuals who are considered Investigators on the project/proposal. Each of these individuals will be considered an Investigator and will be required to complete the necessary forms and complete the training. This form must be completed in a timely manner to allow other Investigators under the project to complete the necessary forms and complete the training before expenditures will be allowed or the proposal will be submitted.
Investigators on new or existing PHS/DOE awards must file a Disclosure of Significant Financial Interest annually and complete the online training every four years.
Investigators who are found to not be in compliance with this policy or have failed to comply with an approved management plan must repeat the training immediately.
The Disclosure of Significant Financial Interest form must be submitted to Debbie Newton, Director of Research and Sponsored Programs. This may be submitted via email or submitted via campus mail in a sealed envelope marked “Confidential.” If it is determined that an Investigator may have a Significant Financial Interest that could directly and significantly affect the design, conduct, or reporting of the PHS/DOE research activity, this Financial Conflict of Interest must be addressed prior to the expenditure of funds or submission of the proposal.