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Financial Conflict of Interest Policy


The “Financial Conflict of Interest on Federal Grants Policy” was designed to establish objective standards that provide a reasonable assurance that the design, conduct, and reporting of research funded by federal grants or cooperative agreements will be free from bias resulting from investigator financial conflicts of interest. The policy applies to all faculty and staff involved in federally funded research at Southern Illinois University School of Medicine (SIUSM) - Springfield. Carbondale based SOM faculty and staff need to follow Office of Sponsored Projects Administration requirements. Federal requirements mandate that all contributors must disclose any potential financial conflict of interest (FCOI) to the University prior to submitting an application for federally funded research. This applies to any individual, regardless of title or position, who is responsible for the design, conduct, or reporting of federally funded research. Please note that this policy applies to other externally- funded activity, including federal flow through projects, for which the funding agency requires an FCOI disclosure.

NOTE: The Office of Grants and Contracts will not be able to submit a federal proposal without a recently completed, grant-relevant, FCOI disclosure form (attestation) for all PIs and personnel listed on the proposal. Additionally, all personnel must complete up-to-date CITI FCOI Training. The CITI FCOI Training is valid for four years.

FCOI Attestation Form found here:

CITI FCOI Training found here:



National Institutes of Health (NIH) Frequently Asked Questions regarding FCOI:

Code of Federal Regulations 42 CFR Subpart F Promoting Objectivity in Research: