Research Conflict of Interest

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 Policy on Research Conflicts of Interest sets forth the processes to identify and manage research Financial Conflicts of Interest.

COI and Human Subjects Research

When submitting IRB applications, investigators must disclose personal and financial interests as required by the reviewing IRB. RCOI reviews disclosed conflicts and communicates required management controls to the reviewing IRB.

Significant Financial Interests

Investigators must disclose when required by the UF Policy on Research Conflicts of Interest. 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:

Salary, royalties or other remuneration paid by UF to the Investigator if the Investigator is currently employed or otherwise appointed by UF;
Intellectual property rights assigned to UF and agreements to share in royalties related to such rights;
Equity interests through investment vehicles, such as mutual funds and retirement accounts, as long as the Investigator does not directly control the investment decisions made in these vehicles;
Income from seminars, lectures or teaching engagements sponsored by a federal, state or local government agency, qualifying U.S. institutions of higher education, an academic teaching hospital, a medical center or a research institute that is affiliated with a qualifying institution of higher education;
Income from service on advisory committees or review panels for a federal, state or local government agency, qualifying U.S. institutions of higher education, an academic teaching hospital, a medical center or a research institute that is affiliated with a qualifying institution of higher education.
Sponsored or reimbursed travel sponsored or paid by a federal, state or local government agency, qualifying U.S. institutions of higher education, an academic teaching hospital, a medical center or a research institute that is affiliated with a qualifying institution of higher education.

Policies

COI Training

The Public Health Service (PHS) Conflict of Interest (COI) regulation requires Principal Investigators and all Key Personnel in PHS-funded projects to complete the Financial Conflict of Interest (FCOI) training before engaging in the research.
1. UF has established a specific FCOI training course DSR 810, which satisfies this PHS requirement.
2. This course can be accessed through myUFL > My Self Service > Training and Development > MyTraining.
Education is required of each individual initially and then every four years
Education is required immediately when:
1. Financial conflict of interest policies are revised in a manner that changes researcher requirements
2. A researcher is new to the organization
3. A researcher is non-compliant with financial conflict of interest policies and procedures

Public Requests for Information: PHS Funded Research

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:

The significant financial interest was disclosed and is still held by the senior/key personnel as defined by this subpart;
The Institution determines that the significant financial interest is related to the PHS-funded research; and
The Institution determines that the significant financial interest is a financial conflict of interest.

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: coi@research.ufl.edu.

If email is not available, please send a written letter of request to the following office address:

Research Conflict of Interest
Research Integrity
University of Florida
Grinter Hall
PO Box 115500
Gainesville, FL 32611-5500

Contact Information

Call UF Research Integrity, Security and Compliance: 352-392-9174 or email us at coi@research.ufl.edu.