COI and Human Subjects Research
When submitting IRB applications, investigators must disclose personal and financial interests as required by the reviewing IRB. The COI Program reviews disclosed conflicts and communicates required management controls to the reviewing IRB.
Significant Financial Interests (SFI)
Investigators must disclose SFI 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 require disclosure of SFI prior to proposal submission (UFIRST prompts confirmation of this disclosure within the proposal workspace)
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 and Threshold
- Remuneration, compensation, and/or other payments for services (e.g. consulting, speaking) when combined with any equity interest in a publicly traded entity which exceeds $5,000
- Remuneration, compensation, and/or other payments for services (e.g., consulting, speaking) from a non-publicly traded entity which 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. Disclosure threshold is 0 / Any Value
- Intellectual property rights and interests which exceeds $5,000
- Sponsored or reimbursed travel* which 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
U.S. PHS Regulation for Objectivity in Research
NSF Proposal & Award Policies & Procedures Guide
Florida Code of Ethics for Public Officers and Employees
UF Policy on Conflicts of Commitment and Conflicts of Interest
UF Policy on Research Conflicts of Interest
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 (5) business days of a request, of information concerning any significant financial interest disclosed to the Institution that meets the following three (3) 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 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 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: uf-coi@ufl.edu
If email is not available, please send a written letter of request to the following office address:
Conflicts of Interest Program
Research Integrity, Security and Compliance
University of Florida
PO Box 115500
Gainesville, FL 32611-5500