The Research Conflict of Interest Program (RCOI) reviews and manages Significant Financial Interests that have the potential to bias research. The program ensures UF’s compliance with sponsor COI regulations. UF Research Policy on Disclosure of Financial Interests and Management of Conflicts of Interest Related to Research sets forth the processes to identify and manage research Financial Conflicts of Interest.
On a rolling basis, groups of UF employees become eligible to disclose through UFOLIO. More information, including what to disclose, how to navigate the system and who is currently eligible to disclose in UFOLIO is available on the UF COI Program website: https://coi.ufl.edu.
When submitting IRB applications, investigators must disclose personal and financial interests as required by the reviewing IRB. RCOI uses the guidelines found here when reviewing potential conflicts of interest related to Interventional Human Subject Research.
Investigators must disclose when required by the UF Research Policy on Disclosure of Financial Interests and Management of Conflicts of Interest Related to Research. UF Investigators, regardless of research funding sources, must disclose new SFIs related to their Institutional Responsibilities within 30 days of acquisition or discovery and complete UF’s annual disclosure process. Certain sponsors (PHS and NSF) require disclosure of SFIs prior to proposal submission.
An SFI includes a financial interest consisting of one or more of the following interests of an Investigator (and those of the Investigator’s Immediate Family Members) related to their Institutional Responsibilities, when combined for the 12 months preceding the disclosure date, from a single Entity:
|Nature of SFI||Disclosure Threshold|
|Remuneration, compensation, and/or other payments for services (e.g. consulting, speaking) when combined with any equity interest in a publicly traded entity.||Exceeds $5,000|
|Remuneration, compensation, and/or other payments for services (e.g., consulting, speaking) from a non-publicly traded entity.||Exceeds $5,000|
|Equity interests in a non-publicly traded company (e.g. start-up company). Equity includes stock, stock options, or other ownership interest.||0 / Any Value|
|Intellectual property rights and interests||Exceeds $5,000|
|Sponsored or reimbursed travel*||Exceeds $5,000|
*Disclosure of sponsored or reimbursed travel applies to PHS-funded researchers only
SFI Does Not Include:
When an Outside Activity or Financial Interest disclosed in UFOLIO relates to research, the COI Program reviewer marks the disclosure for ancillary review, and it routes to the RCOI Administrator. If additional information is required to determine whether your disclosure is a Significant Financial Interest and, if so, whether it relates to your UF research, our office will contact you directly.
Prior to engaging in research related to your Significant Financial Interests, contact the RCOI Administrator if you have not yet received a final management plan. Amber Moore, Assistant Director, is available at 352-273-3104 or email@example.com.
Pursuant to the PHS regulation for Promoting Objectivity in Research, UF will provide a written response to any requestor within five business days of a request, of information concerning any significant financial interest disclosed to the Institution that meets the following three criteria:
Pursuant to the PHS regulation, COI-R will provide: the Investigator’s name; the Investigator’s title and role with respect to the research project; the name of the entity in which the significant financial interest is held; the nature of the significant financial interest; and the approximate dollar value of the significant financial interest, or a statement that the interest is one whose value cannot be readily determined through reference to public prices or other reasonable measures of fair market value. COI-R will note in its written response that the information provided is current as of the date of the correspondence and is subject to updates.
To submit a request, please email: firstname.lastname@example.org.
If email is not available, please send a written letter of request to the following office address:
Research Conflict of Interest
University of Florida
PO Box 115500
Gainesville, FL 32611-5500
Entity: Any business, company, or other organization, whether public or private, including without limitation any partnership, corporation, limited liability corporation, unincorporated association, or other institution or organization, whether for-profit or not-for-profit.
Financial Conflict of Interest (FCOI): A Financial Conflict of Interest exists when UF, through its Research Conflict of Interest Administrator, reasonably determines that an Investigator’s Significant Financial Interest is related to a funded research project and could directly and significantly affect the design, conduct or reporting of the funded research, or present the appearance thereof.
Human Subjects Research: Any investigation or organized activity, regardless of funding source, involving patient oriented research, behavioral research, or epidemiological, outcomes, or health services research, which requires approval by an Institutional Review Board.
Immediate Family Member: Includes an Investigator’s spouse, domestic or civil union partner, and dependent children.
Institutional Responsibilities: Include professional activities that relate to an Investigator’s responsibilities on behalf of UF, such as research, teaching, institutional committee memberships, professional practice, and administrative activities and responsibilities for UF.
Investigator: Includes anyone responsible for the design, conduct, or reporting of research, regardless of title or position, and their Immediate Family Members.
Research Conflict of Interest (RCOI) Administrator: The designated institutional official responsible for implementing the Policy on Disclosure of Financial Interests and Management of Conflict of Interests Related to Research, reviewing Significant Financial Interests and managing FCOI.
Subrecipient: A legal entity that receives a Subcontract from a pass-through entity to carry out a portion of a sponsored program. A Subrecipient has responsibility for programmatic decision making; has its performance measured in relation to whether objectives of a programmatic scope of work were met; and is responsible for adherence to applicable sponsored program requirements specified in the sponsored award, as opposed to providing routine goods or services for the benefit of the pass-through entity.