Financial Conflict of Interest Policies and Procedures

A conflicts of interest in research may occur when outside financial interests compromise or appear to compromise the professional judgment of the researcher during the design, conduct or reporting of research. Having a conflict of interest is not discouraged or necessarily considered to be a problem if it is managed appropriately. Fort Hays State University seeks to maintain the appropriate balance between all competing interests that may have the potential to bias the design, conduct or reporting of research. Conflicts of interest can be a serious problem if they are not made known to the university. If discovered, an undisclosed conflict of interest may result in concerns regarding the integrity of the research, and harm the reputation of the researcher and the university.

The US Public Health Service changed its regulations on Financial Conflicts of Interest (FCOI) in August 2012. Important changes include:

  • Lower dollar thresholds for the disclosure of financial interests
  • Increased disclosure requirements for travel reimbursements
  • New conflict of interest training requirements
  • New public accessibility requirements
  • "Significant financial interests" now includes interests related to any aspect of a PHS-funded researcher's institutional responsibilities
  • New regulations apply to current financial interests as well as those 12 months preceding the disclosure.

The PHS FCOI regulations apply to PHS-funded research. Significant financial interests disclosures and FCOI training must be completed PRIOR to submission of requests for PHS funds, and applies to all new and continuation awards. Affected agencies include:

  • National Institutes of Health (NIH)
  • Department of Health and Human Services (DHHS)
  • Agency for Healthcare Research and Quality (AHRQ)
  • Centers for Disease Control and Prevention (CDC)
  • Health Resources and Services Administration (HRSA)
  • Indian Health Service (IHS)
  • Substance Abuse and Mental Health Services Administration (SAMHSA)
  • Agency for Toxic Substances and Disease Registry (ATSDR)
  • Center for Medicaid and Medicaid Services (CMS)

Additionally, some non-federal organizations such as the American Heart Association, American Cancer Society, Susan G. Komen for the Cure and others also require FCOI compliance. Check with the Office of Scholarship and Sponsored Projects if you are not certain.

The FHSU FCOI policy and procedures are part of a process to identify and manage financial conflicts of interest in compliance with agency specific regulations, minimizes burden on faculty and administrators, and appropriately manages risk. It is our intent to foster a culture of compliance, fairness and transparency.

FCOI Policy

FCOI Disclosure Forms

FCOI Process

CITI training in FCOI is available.


Step 1: Go to

Step 2: Click on register

Step3: Select Fort Hays State University from the participating institutions drop down menu.

Step 4: Complete the remaining information, create a user name and password and submit.

Step 5: When you login to CITI, you will be taken to the FHSU page. Select the appropriate course modules and complete your training!


National Institutes of Health FCOI Website has many resources!

NIH web-based FCOI Tutorial

Federal Register Notice



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