There are two primary types of disclosures, Financial Conflicts of Interest (FCOI) and non-financial Conflicts of Commitment (COC). As an applicant for and/or recipient of certain federal or state research funds, you are required to complete disclosures related to each using this form.
Conflict of Commitment (COC) means a non-financial conflict of interest in which an individual accepts or incurs conflicting obligations, whether domestic or foreign, between or among multiple employers or other entities. COC includes conflicting commitments of time and effort, including obligations to dedicate time in excess of institutional or funding agency policies or commitments. COC also includes obligations to improperly share information with, or to withhold information from, an employer or sponsoring agency, as well as other conflicting obligations that threaten research security and integrity.
Financial Conflict of Interest (FCOI)
means a significant financial interest
that has potential to directly affect the design, conduct or reporting of sponsored research. It refers to anything of monetary value, including, but not limited to, salary or other payments for services (e.g., consulting fees or honoraria); equity interest (e.g., stocks, stock options or other ownership interests); and intellectual property rights (e.g., patents, copyrights and royalties from such rights).
The term does not include:
- salary, royalties or other remuneration from the applicant organization;
- income from seminars, lectures, or teaching engagements sponsored by public or non-profit entities;
- income from service on advisory committees or review panels for public or nonprofit entities;
- an equity interest that, when aggregated for the investigator and the investigator’s spouse and dependent children, meets both of the following tests: does not exceed $10,000 in value as determined through reference to public prices or other reasonable measures of fair market value, and does not represent more than a 5% ownership interest in any single entity; or
- salary, royalties or other payments that, when aggregated for the investigator and the investigator’s spouse and dependent children, are not expected to exceed $10,000 during the prior twelve-month period.