Financial Conflict of Interest in Research: Declaration and Determination Process

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Financial Conflict of Interest in Research (FCOIR) Declaration

When submitting proposals for sponsored activities through Electronic Proposal Clearance System (E-PCS), the Principal Investigator identifies Investigators who are Key Personnel responsible for the design, conduct or reporting of the proposed project.

All Investigators/Key Personnel are required to submit a Financial Conflict of Interest in Research (FCOIR) Declaration, reporting to the University all Significant Financial Interests (SFI) that relate in any way to their institutional responsibilities, and any other work or service for any outside entities.

For all Investigators/Key Personnel:

  • The FCOIR Declaration must be submitted at least annually (every 365 days)
  • The FCOIR Declaration must remain current; updates must occur within 30 days of any change in SFI (new or existing) and/or outside work or service. 
  • The FCOIR Declaration must be current before the E-PCS record can be finalized and the proposal submitted to the sponsoring agency.

Upon successful completion and certification of the FCOIR Declaration, the Investigator/Key Personnel will receive a confirmation email from At the time of annual FCOIR Declaration or during updates, the Investigator/Key Personnel is required to review their previous FCOIR Declaration and revise as appropriate.

Investigators/Key Personnel can access the FCOIR Declaration through the link under Messages Menu in E-PCS.

Financial Conflict of Interest in Research (FCOIR) Determination

A Significant Financial Interest (SFI) declared by an Investigator is not by definition a Financial Conflict of Interest in Research. The majority of declared SFIs typically are not determined to represent actual conflicts of interest.

All Significant Financial Interests declared by Investigators will be reviewed by Research Compliance Services (RCS) alongside all sponsored projects for which the Investigator is responsible for the design, conduct and reporting of research, and considered in light of the Investigator’s institutional responsibilities. 

RCS will make an initial determination on whether a declared SFI is related to that Investigator’s sponsored activities, and whether that SFI presents a potential or actual conflict of interest in research.  This initial determination will be based on UO policy guidelines and federal regulations. If RCS determines that an SFI does not represent any financial conflict of interest in research for an Investigator, the determination is documented and the Investigator will be so notified via email.  No further action is required of that Investigator at that time. 

Any new award will be reviewed by RCS against all identified Investigators’ SFI Declarations to determine if there are any FCOIRs related to that new award.

If an Investigator has no Significant Financial Interests on the Declaration eForm, the process ends and no further action is required of the Investigator until the next annual Declaration is due, unless the Investigator identifies or acquires a new Significant Financial Interest in the interim. In instances of acquiring a new Significant Financial Interest or an SFI change, Investigators should provide the SFI details via the SFI Declaration eForm.