Both sponsors and federal funding agencies require the review of significant financial interests (SFIs) as they relate to the scope of work to promote objectivity in research. These regulations and policies require the University to assess the SFI and determine if the interests are related to the research, and if the interests meet the definition of a Financial Conflict of Interest (FCOI). If an FCOI is identified, it must be managed.
Note: The Policy on MU Procedures Conflict of Interest and Conflict of Commitment applies to all University of Missouri employees for Conflict of Interest and Conflict of Commitment (COI/COC). In some situations, employees may be required to report activities/income that are not required to be reported in their role as an investigator.
Funding agencies requiring review
PHS: “Investigator means the project director or principal Investigator and any other person, regardless of title or position, who is responsible for the design, conduct, or reporting of research funded by the PHS, or proposed for such funding, which may include, for example, collaborators or consultants.”
DOE: “Investigator means the principal Investigator (PI) and any other person, regardless of title or position, who is responsible for the purpose, design, conduct, or reporting of a project funded by DOE or proposed for funding by DOE. DOE program offices have the discretion to expand the definition to include also any person who participates in the purpose, design, conduct, or reporting of a project funded by DOE or proposed for funding by DOE. Such expansion will be specified in the applicable funding opportunity announcement and/or terms and conditions of the financial assistance award.”
NSF: “The term investigator means the principal investigator, co-principal investigators, and any other person at the institution who is responsible for the design, conduct, or reporting of research or educational activities funded or proposed for funding by NSF.”
Before an investigator can start working on an award, the COI Office must be notified. The investigator will need to have a current disclosure and have current COI training.
- With regard to any publicly traded entity, a significant financial interest exists if the value of any remuneration received from the entity in the twelve months preceding the disclosure and the value of any equity interest in the entity as of the date of disclosure, when aggregated, exceeds $5,000. For purposes of this definition, remuneration includes salary and any payment for services not otherwise identified as salary (e.g., consulting fees, honoraria, paid authorship); equity interest includes any stock, stock option or other ownership interest, as determined through reference to public prices or other reasonable measures of fair market value.
- With regard to any non-publicly traded entity, a significant financial interest exists if the value of any remuneration received from the entity in the twelve months preceding the disclosure, when aggregated, exceeds $5,000, or when the Investigator (or the Investigator’s spouse or dependent children) holds any equity interest (e.g., stock, stock option or other ownership interest); or
- Intellectual property rights and interests (e.g., patents, copyrights), upon receipt of income related to such rights and interests (not paid by the University of Missouri)
For more information, see MU Financial Conflict of Interest (FCOI) Policy.
NOTE: All University Employees must also disclose activities and interest as defined by the Conflict of Interest/Conflict of Commitment Policy.