Research integrity & compliance
Financial Conflict
of Interest
Policy
Requirements for the disclosure, review, management, and reporting of financial interests in PHS/NIH-funded research at the Biomedical Research Foundation.
Compliance at a glance
Three deadlines
to remember.
For Investigators participating in PHS/NIH-funded research.
01
30 days
Disclose
Report a newly discovered or acquired SFI.
02
60 days
Review & report
Complete institutional review and reporting during an award.
03
4 years
Renew training
Complete required Investigator training at least this often.
Compliance at a glance
Three deadlines
to remember.
For Investigators participating in PHS/NIH-funded research.
01
30 days
Disclose
Report a newly discovered or acquired SFI.
02
60 days
Review & report
Complete institutional review and reporting during an award.
03
4 years
Renew training
Complete required Investigator training at least this often.
01 Policy overview
Protecting objectivity in publicly funded research.
This policy implements 42 CFR Part 50 Subpart F for grants and cooperative agreements issued by the National Institutes of Health. It establishes BRF’s process for identifying and addressing financial interests that could affect the design, conduct, or reporting of research.
It applies based on a person’s responsibilities—not title—and may include principal investigators, project directors, collaborators, consultants, subcontractors, and other individuals with independent responsibility for the research.
01 Policy overview
Protecting objectivity
in
publicly funded research.
This policy implements 42 CFR Part 50 Subpart F for grants and cooperative agreements issued by the National Institutes of Health. It establishes BRF’s process for identifying and addressing financial interests that could affect the design, conduct, or reporting of research.
It applies based on a person’s responsibilities—not title—and may include principal investigators, project directors, collaborators, consultants, subcontractors, and other individuals with independent responsibility for the research.
Investigator responsibilities
When must an SFI
be disclosed?
01
At application
Before participating in the project, including for an Investigator who joins after submission.
02
Every year
Submit an updated disclosure on or before September 1 throughout the award period.
03
When circumstances change
Within 30 days of discovering or acquiring a new SFI or reportable sponsored travel.
Investigator responsibilities
When must an SFI
be disclosed?
01
At application
Before participating in the project, including for an Investigator who joins after submission.
02
Every year
Submit an updated disclosure on or before September 1 throughout the award period.
03
When circumstances change
Within 30 days of discovering or acquiring a new SFI or reportable sponsored travel.
02 inside the policy
Explore all 18 sections
This page is a guide. Refer to the official PDF for complete requirements and controlling language.
01
Introduction
Purpose, governing regulations, and BRF’s commitment to objective research.
02
Applicability
Who must follow the policy across BRF’s PHS/NIH-funded research.
03
Definitions
Key terms, including Investigator, SFI, FCOI, and Senior/Key Personnel.
04
SFI disclosure requirements
When and how Investigators must disclose significant financial interests.
05
Review of disclosures
How the Designated Official evaluates disclosures before and during an award.
06
Relatedness & FCOI
How BRF determines whether an SFI relates to research and creates a conflict.
07
Management of FCOIs
Measures BRF may require to protect the objectivity of the research.
08
Monitoring compliance
Ongoing oversight of Investigator compliance with management plans.
09
Public accessibility
Access to this policy and qualifying FCOI information for Senior/Key Personnel.
10
Reporting FCOIs
Initial, annual, revised, and mitigation reports submitted through eRA Commons.
11
Training requirements
Training before participation, every four years, and when circumstances require.
12
Noncompliance
Corrective action, retrospective review, and mitigation when bias is identified.
13
Clinical research
Additional action when unmanaged conflict affects clinical research.
14
Subrecipients
Written agreement and reporting requirements for subrecipient organizations.
15
Maintenance of records
Retention of disclosures, reviews, determinations, and related actions.
16
Enforcement
Consequences for Investigators who do not comply with the policy.
17
Resources
Federal regulations, NIH guidance, training, FAQs, and compliance contacts.
18
Points of contact
How to ask a policy question or disclose a financial interest.
helpful links
Federal guidance
and training.
02 inside the policy
Explore all 18 sections
This page is a guide. Refer to the official PDF for complete requirements and controlling language.
01
Introduction
Purpose, governing regulations, and BRF’s commitment to objective research.
02
Applicability
Who must follow the policy across BRF’s PHS/NIH-funded research.
03
Definitions
Key terms, including Investigator, SFI, FCOI, and Senior/Key Personnel.
04
SFI disclosure requirements
When and how Investigators must disclose significant financial interests.
05
Review of disclosures
How the Designated Official evaluates disclosures before and during an award.
06
Relatedness & FCOI
How BRF determines whether an SFI relates to research and creates a conflict.
07
Management of FCOIs
Measures BRF may require to protect the objectivity of the research.
08
Monitoring compliance
Ongoing oversight of Investigator compliance with management plans.
09
Public accessibility
Access to this policy and qualifying FCOI information for Senior/Key Personnel.
10
Reporting FCOIs
Initial, annual, revised, and mitigation reports submitted through eRA Commons.
11
Training requirements
Training before participation, every four years, and when circumstances require.
12
Noncompliance
Corrective action, retrospective review, and mitigation when bias is identified.
13
Clinical research
Additional action when unmanaged conflict affects clinical research.
14
Subrecipients
Written agreement and reporting requirements for subrecipient organizations.
15
Maintenance of records
Retention of disclosures, reviews, determinations, and related actions.
16
Enforcement
Consequences for Investigators who do not comply with the policy.
17
Resources
Federal regulations, NIH guidance, training, FAQs, and compliance contacts.
18
Points of contact
How to ask a policy question or disclose a financial interest.
helpful links
Federal guidance
and training.
Questions or disclosures
Contact the Designated Official.
Questions or disclosures
Contact the Designated Official.
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