Saint Louis University

FAQs for Financial Conflict of Interest in Research

What is a Financial Conflict of Interest?

A Financial Conflict of Interest in research refers to situations in which significant financial interests or other personal considerations may compromise or could appear to compromise a researcher's professional judgment or integrity.

Who is required to submit a FCOI disclosure?

  • SLU Personnel: All SLU faculty, staff, students (except undergraduates) and other trainees (regardless of pay) listed on an application and/or award for external research funding.
  • Non-SLU Personnel Paid By Subaward: All listed Non-SLU senior/key personnel (regardless of pay) listed on an application and/or award for external research funding.
  • Non-SLU Personnel Not Covered By Subaward: All other Non-SLU individuals responsible for the design, conduct, or reporting of research (if a Non-SLU individual is not identified as senior/key personnel, then the Principal Investigator must determine whether the Non-SLU individual is responsible for the design, conduct or reporting of research).

FCOI Process Map

FCOI Process Map

How do I know if I have a Financial Conflict of Interest that needs to be disclosed?

All faculty, staff and students (except undergraduates) involved in research at Saint Louis University must submit a yearly Financial Conflict of Interest Disclosure Form, whether or not an actual conflict of interest exists. If the office of Responsible Conduct of Research finds that your disclosure results in a potential conflict that needs to be managed, you will be contacted for further information and instruction.

How do I complete an annual Financial Conflict of Interest Disclosure Form?

Please click here for instructions to submit your annual disclosure.

If I have a Financial Conflict of Interest, who decides what needs to be done?

If you are found to have a Financial Conflict of Interest, your case will be reviewed by the Saint Louis University Conflict of Interest in Research Committee (COIRC). The COIRC meets monthly, and decides on appropriate management plans for individual cases. Appropriate management plans ensure the reduction, management, or elimination of the conflict. 

I thought I've already taken CITI training. Do I have to do it again for FCOI?

CITI Financial Conflict of Interest training is not CITI training for Human Subjects. You must take the CITI Conflict of Interest course if you are involved in research.

A lot of people think of CITI training as a course requirement for IRB. Saint Louis University uses CITI (Collaborative Institutional Training Initiative) for other courses as well, including training for animal subjects, Responsible Conduct of Research (RCR), Good Clinical Practice, and the latest Financial Conflict of Interest course. If you are involved in the design, conduct, or reporting of research at SLU, you are required to first complete the Conflict of Interest course through CITI (www.citiprogram.org) and then complete the eFCOI disclosure through eRS (https://ers.slu.edu/ers/logon.aspx).

Please note: It may take up to 48 hours for eRS to recognize that you have completed the CITI Conflict of Interest course.

For instructions on logging in to CITI and adding the Financial Conflict of Interest course, please click here.

For more information on the Financial Conflict of Interest in Research policy and how to submit an eCOI disclosure, please click here.

I have Non-SLU researchers on my project. Do they comply with SLU's FCOI Policy?

In order to comply with federal regulations for conflict of interest, Saint Louis University's Office of Research Integrity must be in receipt of all Non-SLU disclosures prior to the submission of any external application for research funding and before award funds are disbursed.

  • If a Non-SLU researcher will be part of a subaward agreement, then the subcontractor can provide written documentation indicating whether to use its own policy. Satisfactory documentation includes one of the following:
  • If a Non-SLU researcher is involved on the project without the issuance of a subaward or a subcontractor elects to comply with SLU's FCOI policies and procedures, then a Non-SLU COI Disclosure Form is required prior to the submission of any external application for research funding and before award funds are disbursed. FCOI training will also be required at the time of award.

As documented FCOI disclosure is required prior to submission of an application, such disclosure should be initiated at least ten (10) working days in advance of the application deadline for Non-SLU senior/key personnel and other Non-SLU individuals involved in the design, conduct or reporting of research.

Who can I contact if I have a question?

If you have any additional questions about conflict of interest, please refer to the official Saint Louis University Financial Conflict of Interest in Research policy, e-mail COI@slu.edu or call 977-7047.

Other Resources for Financial Conflict of Interest in Research

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