COLLABORATOR CERTIFICATION
FINANCIAL CONFLICT OF INTEREST (FCOI)
OFFICE OF ACADEMIC RESERCH & SPONSORED PROJECTS (OARSP)
The United States Public Health Service (PHS) Financial Conflict of Interest (FCOI) regulations (effective
August 24, 2012) mandate that St. Mary’s University (StMU) determine if a collaborator has a PHScompliant FCOI policy and also requires the collaborator to disclose certain information should a FCOI be
present. StMU will collect this information prior to submission of all federally funded research projects
and all PHS funded projects. StMU will also recheck FCOI status of collaborators prior to issuing a
subaward or a consulting agreement and throughout the project period.
Collaborator Information
Collaborator:
Collaborator’s Investigator: List of Collaborator Investigators (Investigator means the project director or
principal investigator and any other person, regardless of title or position, who is responsible for the
design, conduct, or reporting of federally funded research and PHS funded projects, which may include,
for example, collaborators or consultants.)
Name
Phone #
Email
StMU requires disclosure of financial conflicts of interest from its subcontractors, award
subrecipients, and collaborators. By signing this certification, Collaborator hereby certifies that (check
all that apply):
☐ Collaborator is registered in the FDP Institutional Clearinghouse, Certification of Institutional
Compliance with Public Health Services Financial Conflict of Interest Requirements.
AND
☐ Investigator(s) who will participate in this project will comply with the Conflict of Interests policy(ies)
of Collaborator which:
a) Is publicly accessible, and
b) Is in compliance with Responsibility of Applicants for Promoting Objectivity in Research for
which PHS Funding is Sought (42 CFR Part 50, Subpart F) and Responsible Prospective
Contractors (45 CFR Part 94), and
c) Will ensure that investigator(s) have disclosed their financial interests, and
d) Will ensure that Collaborator has made any Financial Conflicts of Interest (FCOI) information
publicly accessible, and
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COLLABORATOR CERTIFICATION
FINANCIAL CONFLICT OF INTEREST (FCOI)
OFFICE OF ACADEMIC RESERCH & SPONSORED PROJECTS (OARSP)
e) Will ensure that investigator(s) have a current record of completed mandatory FCOI training,
and
f) Will ensure that Collaborator will report identified FCOIs for its investigator(s) in a manner to
allow StMU to report the FCOI as required by regulation.
OR
☐ Investigator(s), who are employed by Collaborator, who will participate in the proposed project will
comply with the Conflict of Interest Policies of St. Mary’s University, and
a) Will complete a STMU Conflict of Interest Disclosure Form, prior to application submission, and
b) Will complete mandatory training for Financial Conflict of Interest (FCOI) in compliance with
Responsibility of Applicants for Promoting Objectivity in Research for which PHS Funding is
Sought (42 CFR Part 50, Subpart F) and Responsible Prospective Contractors (45 CFR Part 94) or
federal research funding prior to release of subaward or consulting agreement.
Reporting:
Entity agrees to submit the following reports to STMU’s Office of Academic Research and Sponsored Projects
(OARSP) in accordance with the due date:
Report Type / Description
Due
CFR Reference
Initial Report: Any Investigator FCOI and
management plan
Prior to proposal
submission
42 CFR Part 50.605(b)(1)
Subsequent Report: Any FCOI subsequently
identified after initial report and
management plan
Within 45 days of
identification
42 CFR Part 50.605(b)(2)
Annual Report: addressing status of FCOI
and any changes to management plan
At request of STMU
42 CFR Part 50.605(b)(1)
42 CFR Part 94.5(b)(1)
42 CFR Part 94.5(b)(2)
42 CFR Part 94.5(b)(1)
Initial and Subsequent reports shall include the information required in 42 CFR Part 50.605(b)(3) or 42 CFR Part 94.5(b)(3)
Questions regarding FCOI can be sent to the OARSP at research@Stmarytx.edu or (210) 436-3720.
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COLLABORATOR CERTIFICATION
FINANCIAL CONFLICT OF INTEREST (FCOI)
OFFICE OF ACADEMIC RESERCH & SPONSORED PROJECTS (OARSP)
Signature
Signature of Collaborator’s Authorized Official: ______________________________________________
Name of Authorized Official (Printed): _____________________________________________________
Title of Authorized Official: ______________________________________________________________
Date: _________________
Return
Please return the completed form(s) to research@stmarytx.edu. If you have questions, please contact the
Office of Academic Research and Sponsored Projects at (210) 436-3720.
For Office Use Only
STMU PI:
STMU Proposal #:
Prime Sponsor:
Proposal Title:
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