Beginning July 1, 2023 investigators will now only need to complete a single, one-time Financial Conflict of Interest (FCOI) disclosure each fiscal year that will apply to all proposals being submitted as opposed to a disclosure for each grant submitted. We anticipate this will significantly reduce the administrative burden for faculty and staff – and especially for those who submit several proposals per year.
If additional potential conflicts are identified within the year, investigators are required to submit an ad hoc disclosure within 30 days of discovering the potential conflict.
Northern Kentucky University’s (NKU) Financial Conflict of Interest (FCOI) policy protects the objectivity and integrity of the work of NKU and its researchers. A financial conflict of interest normally occurs when an employee or student (referred to as “Investigator” going forward) in a relationship with an outside person or organization is in a position to influence the NKU research or associated decisions in ways that could lead directly or indirectly to financial gain or improper advantage for the Investigator or the Investigator’s dependents. These decisions include but are not limited to collection, analysis and interpretation of data, methodology and accuracy of data sharing, hiring of staff, human subject or animal involvement and material purchases for research.
All investigators submitting grants or listed on a grant, through the Office of Research, Grants and Contracts are required to have an active annual Financial Conflicts of Interest/Foreign Interest disclosure on file and complete FCOI training.
The NKU’s Financial Conflict of Interest/Foreign Influence Disclosure form will serve one of two purposes for the Investigator:
For this purpose, NKU defines Investigator to mean the Principal Investigator, Project Director and any other person, regardless of title or position, who is responsible for or involved in the design, conduct or reporting of research.
Investigator includes, but is not limited to, the Principal Investigator, project director, co-principal investigator, and may also include other Senior/Key Personnel, graduate students, trainees, staff members, collaborators, or consultants, depending on the person’s role in the Research.
The primary factors to be used in determining who is an Investigator are the significance of the tasks assigned to the individual about the design, conduct and reporting of the Research and the degree of independence that individual may have in performing such Research-related tasks.
The Principal Investigator will determine which personnel listed on a grant fit the definition of an Investigator. Both internal and external personnel can fit the definition of an Investigator.
As an Investigator, the financial interest of your spouse, dependent children or persons who share financial interests, which could reasonably influence professional responsibilities, is required to be included in your disclosure.
Additional Help for Determining if a Personnel is an Investigator
Always Considered an Investigator
Some individuals with specific roles are ALWAYS considered Investigators and must disclose Significant Financial Interest (SFI).
Subrecipients, while also always considered investigators, must comply with the FCOI policy of their home institution. If their institution does not have a policy, the subrecipients should follow NKU’s policy.
If you still aren’t sure if your personnel fits the definition of an Investigator, consult the checklist below, or contact RGC.
If you have any questions regarding the definition of “Investigator,” please contact the Manager of Research Compliance, Anita Southwick, at (859) 572-5168 or email@example.com.
A financial interest is anything of monetary value, related to an Investigator's University responsibilities, whether or not the value is readily ascertainable, in any of these categories:
• Remuneration or compensation (e.g., salary, consulting fees, honoraria, etc.) from a public or private company.
• Equity (e.g., stock, stock options or other ownership interest) in a public or private company.
• Intellectual property rights (e.g., patents, copyrights) and any royalties and licensing income from such rights.
• A position in an outside entity that gives rise to a fiduciary duty, such as director, officer, partner, trustee, employee or any position of management.
• Any reimbursed or sponsored travel for Investigators with Public Health Service (PHS) funding.
A financial interest DOES NOT include:
• Salary, royalties or other remuneration from NKU.
• Income or travel from seminars, lectures or teaching engagements sponsored or paid by a public government agency, an Institution of higher education, an academic teaching hospital, a medical center or a research institute that is affiliated with an Institution of higher education.
• Income or travel from service on advisory committees or review panels sponsored or paid by a public government agency, an Institution of higher education, an academic teaching hospital, a medical center or a research institute that is affiliated with an Institution of higher education.
• Income from investment vehicles, such as mutual funds and retirement accounts, as long as the Investigator does not directly control the investment decisions made in these vehicles (e.g. 403b plan or target date retirement fund).