Financial Disclosure for PHS-Funded Investigators
Financial Disclosure for Investigators
Health and Human Services (HHS) has issued regulations, 42 CFR Part 50 Subpart F, on financial disclosure for Public Health Service (PHS)-funded investigators. Additional financial disclosure and training is required for anyone involved in the design, conduct, and analysis of PHS-funded research. This includes the Principal Investigator (PI), co-PIs, academic professional research staff, postdoctoral research associates, and graduate research assistants. If your research or employment at UIS is funded by the Department of Health and Human Services, Public Health Services, or the National Institute of Health (NIH) you will be required to complete a financial disclosure form and complete mandatory training. The financial disclosure form is designed to assist the investigaor(s) to properly disclose any potential significant conflict of interest (SFI) that is related to the investigator, the investigators ’s spouse, and dependent children that reasonably appear to be related to the investigator’s institutional responsibilities. This disclosure must occur:
- no later than at the time of application for PHS-funded research;
- within thirty (30) days of discovering or acquiring (through purchase, marriage, or inheritance) a SFI; and
- at least annually, in accordance with the specific time period prescribed by the Institution, during the period of award.
Pre-Award Financial Disclosure When an Investigator is preparing a proposal for submission or renewal of a PHS-funded grant, the PI and Co-PI (if applicable) will be asked to certify that the financial and travel certification disclosures are current for all investigators expected to participate in the project. This certification must be included with the UIS Internal Clearance Form (doc) when submitted to the Office of Grants, Contracts, and Research Administration for approval. Investigators must use the PHS Investigator Financial Interest (pdf) for disclosure. The completed form should be sent to the Office of Grants, Contracts, and Research Administration or emailed to firstname.lastname@example.org If a completed form discloses activities that require review, the Vice Chancellor of Academic Affairs and Provost or his/her designee will meet with investigator’s assigned Primary Reviewer on identification of any SFI as needed, and will work with the Primary Reviewer to manage any SFI that is identified. The list of primary reviewers can be found at the following link:
Prior to initial award or renewal, the PI will be required to certify that financial disclosures, travel disclosures, and required training are current for all investigators participating in the project.
Travel Disclosure for PHS Funded Researchers Investigators of Public Health Services (PHS) funded grants are required to disclose each occurrence of any reimbursed or sponsored travel related to their institutional responsibilities. This disclosure does not apply to travel that is reimbursed or sponsored by sources excluded by Department of Health and Human Services (HHS) regulations. Excluded sources include federal, state, or local government agencies; and Institute of Higher Education as defined by 20 U.S.C. 1001(a); an academic teaching hospital; a medical center; or a research facility affiliated with an Institution of Higher Education. Travel associated with significant financial interests such as consulting, paid service on a Board of Directors or Advisory Committee, or other paid outside activities should generally be reported in conjunction with disclosure of the financial interest or paid outside activity. Please use the PHSInvestigatorFinancialInterest (pdf) for this purpose. The disclosure form for Travel Related to PHS Sponsored Research (doc) can be used to disclose each travel event. Please remember that the PHS regulation has a $0 de minimis and the reporting requirement is for the previous 12 months. Required Training for Investigators The regulations require that:
- Training must be completed by all new investigators before engaging in PHS funded research; and
- Training must be completed by all investigators currently involved in PHS projects prior to renewal.
In addition, training must be completed every four (4) years following initial training and when any of the following conditions apply:
- The University revises the Conflict of Commitment and Interest policy or any procedures that may affect the requirements of the Investigator to comply with PHS regulation;
- The University determines that an Investigator is in non-compliance with the Conflict of Commitment and Interest policy or with an existing approved management plan.
There are two required components for the training at UIS. The investigator(s) will complete an online tutorial provided by the National Institute of Health (NIH) Office of Extramural Research on Financial Conflict of Interest (FCOI) and review the current University of Illinois policy on Conflict of Commitment and Interest. Please click on the following links:
Upon completion of the NIH tutorial the investigator will be able to print a Certificate of Completion. In addition, after reviewing the University of Illinois policy on Conflict of Commitment and Interest policy the investigator will be able to complete a form documenting completion of the review. The form is available at the following link:
Send a copy of the Certificate of Completion from the NIH tutorial and a copy of the Investigator Training Document Form to:
University of Illinois at Springfield Grants, Contracts & Research Administration One University Plaza, MS PAC 525 Springfield, Illinois 62703-5407
NOTICE If you are completing an application for a PHS sponsored grant, include documentation of completion of training with the Internal Clearance Form (doc) when routing for approval. If your PHS-funded research or PHS sponsored grant application includes human subjects or animals, submit documentation of completed training with your protocols to the Institutional Review Board or the Institutional Committee for the Care and Use of Animals.
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