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Financial Conflict of Interest

In compliance with the Public Health Services[1] Financial Conflict of Interest policy, any research project sponsored by Public Health Services, either directly or through a subaward, is subject to additional compliance requirements.  If you plan to submit a proposal for PHS funding, please contact Sponsored Programs with questions about compliance requirements. 

The following requirements must be met by each individual who functions as key personnel[2] prior to the submission of a proposal for PHS-funded research:

  • A Financial Interests Report must be submitted online by all key personnel prior to the proposal being submitted and must be re-submitted annually for as long as an award is active.  In the event that outside financial or managerial interests for the individual or his or her family change in a way that results in different answers to any of the questions asked in the report, a revised report must be submitted within 30 days of the change. 
  • CITI Financial Conflicts of Interest training must be completed by all key personnel prior to the proposal being submitted.  Instructions for registering for the training as part of a new CITI account registration or adding to the course to an existing account, please click here.  This training must be completed every three years, and documentation must be attached to each report submission.  

In the event that a project is not determined to be subject to this policy when submitted in collaboration with another institution, policy compliance may be enforced upon receipt of a subaward.  For any subaward that includes compliance requirements with this policy, these procedures must be followed prior to an award being signed and prior to funding being accessed by EKU investigators.  

Any member of the general public who wishes to request information about financial conflicts of interest that have been disclosed under the PHS Financial Conflict of Interest Policy may do so by contacting Sponsored Programs, and a response will be provided within five business days. 

[1]Agencies within the Public Health Service: 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), Substance Abuse and Mental Health Services Administration (SAMHSA)

[2]Key Personnel: All EKU faculty or staff who have a significant role in carrying out the proposed project.  Key personnel include the principal investigator and any and all co-PIs.  It also includes any faculty and professional staff who are contributing more than 5% effort to the project, either as a direct charge to the project or as committed cost sharing.

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