9.22 / Disclosure of Financial Conflicts of Interest for Research Subject to Public Health Service Financial Conflict of Interest Regulations

Effective: April 04, 2013Last Revised: January 30, 2018

  1. Purpose

    The purpose of this policy is to implement the 2011 Public Health Service (PHS) regulations related to the promotion of objectivity in research; the full set of regulations are published in the Federal Code of Regulations (42 C.F.R. Part 50 Subpart F).

  2. Applicability

    This policy applies to Wichita State University and any individual meeting the definition of Investigator, as defined by 42 C.F.R. Part 50 Subpart F, regardless of employment type or status. This policy also applies to Non-PHS agencies that use the PHS regulations for funded research.

  3. Policy

    The University is committed to ensuring the integrity of research conducted by its investigators, collaborators, consultants and sub-awardees. To that end, this policy in combination with Section 3.04 Commitment of Time, Conflict of Interest, Consulting and Other Employment, strives to manage situations that create, may create or have the appearance of creating significant conflicts of interest.

  4. Reporting

    Investigators are required to have a completed disclosure of Significant Financial Interests (SFI) on file:

    • Prior to submission of an application to any agency subject to PHS FCOI (or Public Service Act, etc.)
    • At least annually during the period of the award.
    • Within thirty (30) days of discovering or acquiring a new SFI.

  5. Training

    Investigators are required to complete financial conflict of interest training when one or more of the following conditions are met:

    • Prior to engaging in PHS related research;
    • No less than every four (4) years;
    • Immediately if University makes material changes to its FCOI policy, an Investigator is new to the University or an Investigator is not in compliance with this policy or a related management plan.

  6. Management Plans and Resolution of Conflicts

    University will use the procedures outlined in Section 3.04, Commitment of Time, Conflict of Interest, Consulting and Other Employment.

  7. Acknowledgement of University Policy

    Employees who make application for external support for their research, educational, or service projects will be required to specify on the University Proposal Routing Form that they have read the conflict of interest policy and have filed a disclosure report before their application is sent to the potential sponsor.

  8. Enforcement of University Policy

    Failure to submit the required disclosure form will result in denial of the opportunity to submit research proposals to external funding agencies subject to PHS FCOI (or Public Service Act or CFR, etc.) until the form is submitted and may result in discipline in accordance with University procedures.

  9. Related Policies and References

    1. Related WSU Policies

    2. Related WSU Training

    3. External Policies and Regulations