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Financial Conflict of Interest

In accordance with EKU Policy 4.4.1: Conflicts of Interest, the University enforces additional compliance requirements related to conflicts of interest for projects that are sponsored by agencies with additional requirements.  These requirements include, but are not limited to, the following: 

A Financial Interests Report must submitted by each individual who functions as an investigator[2] prior to the submission of a proposal for PHS-funded research or for NSF-funded research or educational activities.

  • 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. 

Investigators on proposals for PHS-funded research are also required to complete training on financial conflicts of interest, and investigators and other key personnel for projects sponsored by other agencies are also encouraged to complete training.  

  • CITI Financial Conflicts of Interest training must be completed by ALL investigators prior to a proposal being submitted for PHS funding and other agencies requiring training.  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 proposal is not determined to be subject to additional requirements, the additional requirements will be enforced upon receipt of an award when applicable. In such cases, the additional compliance requirements must be satisfied 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 documented 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]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 or proposed for funding by an external sponsoring agency.  This definition also applies to collaborators and consultants. In classifying an individual as an investigator, the role of the individual must be considered rather than the individual's title.

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