The United States (US) Public Health Service (PHS), as well as some other US sponsoring agencies, require all awardee universities and researchers, including those outside the US, to comply with the requirements of the US federal PHS regulations on financial conflicts of interest (FCOIs) (i.e. Responsibility of Applicants for Promoting Objectivity in Research and Responsible Prospective Contractors) as a condition of the award.
These regulations require that participating researchers be trained in the regulations and disclose to the University of Toronto (U of T) their significant financial interests. U of T is required to do the following:
- Review disclosed significant financial interests to determine whether they constitute FCOIs
- Manage any FCOIs and report them to the sponsoring agency
- Monitor and enforce researcher compliance with the Regulations
- Maintain records and make certain information publicly accessible
The regulations also explicitly require that the awardee have a written enforced policy on FCOIs for PHS-funded research that complies with the regulations. U of T has accordingly developed PHS FCOI Procedures in two parts, one for Investigators and one for U of T, under U of T’s Policy on Ethical Conduct in Research. The PHS FCOI procedures can be found in the Forms & Downloads section below.
The procedures apply only to those researchers who apply for or choose to participate in research funded by US PHS sponsoring agencies (or other agencies adopting the Regulations), and only to their research activities that are funded by these agencies.
Where research is funded by the US National Science Foundation (NSF), which occurs only through a sub-award, ordinarily the NSF Conflict of Interest policy in the NSF Proposal & Award Policies & Procedures Guide applies. The policy requires that the subrecipient has an appropriate written and enforced policy. U of T has accordingly developed a guideline under U of T’s Policy on Ethical Conduct in Research. This Guideline sets out the obligations of researchers and U of T when the NSF policy applies to NSF-funded research. The Guideline applies only to those researchers who apply for or choose to participate in research to which the NSF policy applies, and only to their research activities that are covered by the NSF policy.
- Review and process FCOI declarations
- Review and approve FCOI management plans
Contact the VPRI staff member who is managing the application or resulting funded research agreement.
