02 - Financial Conflict of Interest In Research

Marian University is required by federal law to have a written and enforced Financial Conflict of Interest (FCOI) Policy addressing the avoidance, disclosure, management, and resolution of financial conflicts of interest in research and sponsored programs. The objective of the federally-mandated FCOI policy is to promote objectivity in research by establishing standards providing a reasonable expectation that the design, conduct, and reporting of research, as well as other research-related activities, will be free from bias resulting from investigator financial conflicts of interest. MU’s FCOI in Research policy is administered through the Research & Scholarship Administration’s Office of Research Operations, Integrity, and Compliance. The full policy is available at this link Download link and the major points are summarized below.

• • All individuals (regardless of title or position) responsible for proposing, conducting, or reporting research and scholarly activity that is under the financial oversight of the MU Research & Scholarship Administration, its offices, and/or the MU Grants Management Office must complete an online training course related to conflicts of interest at least every four years. Additionally, investigators must complete the FCOI Disclosure Form (link Download link) and submit it for review by the MU Research Integrity Officer (RIO) as follows: 1) prior to the submission of a funding proposal or 2) for ongoing funded activities, annually throughout the lifetime of the funding during the disclosure window (September 1 - September 21). Individuals joining an ongoing funded activity must submit the disclosure prior to joining the said activity. Disclosures must be updated as soon as possible but no more than 30 days after a significant financial interest arises. Disclosures shall also be updated as soon as possible when an existing significant financial interest ends or materially alters.

• • The RIO will use federal guidelines to determine whether an investigator’s significant financial interest is related to his or her research or sponsored program activities and, if so, whether the significant financial interest is a conflict of interest. If a conflict of interest exists, the RIO shall facilitate the implementation of a management plan which, at a minimum, will require investigators disclose conflicts of interest in each public presentation of the research. The RIO shall monitor investigator compliance with the management plan on an ongoing basis until the completion of the research project.