Financial Conflict of Interest Policy

Background

Federal Legislation requires institutions of higher education to comply with Financial Conflict of Interest (FCOI) training and reporting requirements for sponsored programs (see 42 CFR Part 50, Subpart F and 45 CFR Part 941). Bradley University has implemented the following Policy to ensure compliance with federal requirements.

Bradley’s FCOI Policy

Bradley University investigators seeking or receiving funding from an external entity must:

1. Complete CITI Program Conflict of Interest (COI) training at least once every four years.
2. Submit to OSP a Significant Financial Interest (SFI) Disclosure form at least once every 12 months.
3. Submit to OSP a revised SFI form within 30 days from when a new SFI was discovered or acquired and when changes occur to previously disclosed SFIs.
4. Cooperate with any actions undertaken to manage identified financial conflicts of interest related to the proposed initiative or activity.

^*Please Note: This policy is separate from the Bradley University’s Conflict of Commitment and Conflict of Interest Policy and procedures, and pertains specifically to Bradley University investigators seeking external funding support for their work.

1. https://www.ecfr.gov/current/title-42/chapter-I/subchapter-D/part-50/subpart-F

Forms and Resources