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UMSL encourages faculty and staff collaboration with teaching, government agencies, and industry. External relationships establish valuable connections, enrich research, expand career opportunities for students, and provide a mechanism for the translation of University developed intellectual property into commercial ventures. However, this dual relationship can lead to inherent conflicts of interest. The Collected Rule 330.015 for Conflict of Interest requires employees complete a disclosure of outside interests at least annually and as any changes or new acquisitions arise.
What is the University of Missouri-St. Louis
Conflict of Interest Policy?
- University of Missouri System Policy on Conflict of Interest (Collected Rules and Regulations 330.015) Applicable to All University Employees
- University of Missouri System Policy on Conflict with the Interests of Federal Grant Agencies (Collected Rules and Regulations 420.030) Applicable to PHS-funded and NSF-funded Researchers
- University of Missouri-St. Louis Procedures on Conflict of Interest
- University of Missouri-St. Louis Student Awareness Policy
What is Considered Reportable?
Examples of outside interests that would be considered reportable, can be found here. The list is not all inclusive and there may be differences that change the outcome. Please contact the Compliance Manager at 516-5972, if you are unsure if an outside interest is reportable.
How do I Submit or Update my Outside Interest Disclosure?
To submit, log into eCompliance using your SSO or email address and password at: https://umsl.ecompliance.umsystem.edu/login
A user guide that provides step by step submission instructions, can be found here.
A user guide that provides step by step submission instructions for updating your disclosure, can be found here.
What Happens After I Submit?
The Outside Interest Disclosure Review Flowchart illustrates what happens following the submission of disclosures in eCompliance.
Special Considerations for Grants and Technology Transfer
The FCOI guidelines and forms discussed here are applicable to all research funding by the Public Health Service (PHS) and the National Science Foundation (NSF). See a list of PHS agencies in the right-hand column of this page.
In response to increased public scrutiny and concern about conflicts of interest at research institutions, the Public Health Service (PHS) has redrafted its conflict of interest regulations (42 CFR Part 50 Subpart F and 45 CFR Part 94). This increased public scrutiny is a result of both the increase in relationships between researchers and industry and the increased rate at which research is brought from the bench to the market place. Strengthening the existing regulation on managing financial conflicts of interest is key to assuring the public that the institutions PHS supports are taking a rigorous approach to managing the essential relationships between the government, federally funded research institutions, and the private sector. These revised regulations were effective as of August 24, 2012.
What are the responsibilities of Investigators under the PHS Regulation?
- All Investigators are required to complete CITI Conflict of Interest training every four (4) years.
- All Investigators must submit an annual Outside Interest Disclosure Form (OIDF) in eCompliance prior to submitting any proposals for PHS-funded research and each year thereafter. Proposals will not be submitted if all Investigators do not have a current OIDF on file. Collaborators and Consultants are also required to complete an annual Outside Interest Disclosure Form (OIDF) in eCompliance for Sponsored Projects.
- Investigators participating in PHS-funded projects are required to disclose travel expenses funded by an outside entity, including reimbursed travel, when such expenses exceed $5000 when aggregated over the last 12 months. Once the $5000 threshold for sponsored travel from a single entity has been reached, a Sponsored Travel Report must be submitted through eCompliance describing the travel sponsored by that entity.
- INVESTIGATOR FORM FCOI-2 is required for all submissions identifying all investigators. It is the responsibility of the Principal Investigator to insure that all “investigators” have completed Conflict of Interest training.
PHS has provided the following guide for determining who is an investigator.
§50.603 Definitions: Investigator means the project director or principal Investigator and any other person, regardless of title or position, who is responsible for the design, conduct, or reporting of research funded by the PHS, or proposed for such funding, which may include, for example, collaborators or consultants.
PHS comments about the Investigator definition:
“…the definition of “investigator” has been revised in the final rule to emphasize that Institutions should consider the roles of those involved in research and the degree of independence with which those individuals work.”
“…we note that the definition refers to the function of the individual on the PHS-funded project; i.e. his/her responsibility for the design, conduct or reporting of the PHS-funded research, and not to his/her title or the amount and /or source of remuneration.” This broad definition may include post-doctoral associates, graduate students, etc.
Prior to Submission for all Federal and Federal Flow-Through Funding from PHS and NSF:
STEP 1: CITI Training, Conflict of Interest Mini Course
Required for all investigators identified on the UMSL Investigator Form. Training is required prior to submission of the proposal and every four (4) years thereafter. Log into eCompliance, select the Conflict of Interest module, then click on Conflict of Interest Training on the right side of the screen. After clicking, there will be instructions available for how to select the correct training.
STEP 2: Submit Outside Interest Disclosure in eCompliance
STEP 3: UMSL Investigator Form
Must be included with the your signature page and PeopleSoft submission pages. NOTE: The ORA will ask you to review the Investigator Form at time of award and update the form whenever changes occur throughout the life of the project. UMSL Investigator Form.
Prior to Submission for Funding from Non-Federal and Other Sponsors Not Adopting the New FCOI Regulations:
STEP 1: Submit Outside Interest Disclosure in eCompliance
Required for all investigators identified on the UMSL Investigator Form.
- University of Missouri Collected Rules and Regulations, Policy 330.015 Conflict of Interest and Policy 420.030 Conflict with the Interests of Federal Grant Agencies
- Summary of Conflict of Interest Changes
- The U.S. Department of Health and Human Services (HHS) has issued a final rule in the Federal Register that amends the Public Health Service (PHS) regulations on Responsibility of Applicants for Promoting Objectivity in Research for which PHS Funding is Sought (42 C.F.R. Part 50, Subpart F) and Responsible Prospective Contractors (45 C.F.R. Part 94). The final rule includes a compliance implementation timeline as outlined in the "Compliance Dates" section.
- NIH Frequently asked Questions
- General inquires about the FCOI regulation for grants and cooperative agreements may be directed to: FCOICompliance@mail.nih.gov.
- General inquires about the FCOI regulation for contracts should be directed to FCOIContracts@mail.nih.gov.
Employee interactions with the private sector carry potential for conflict of interest, or the perception of such conflicts. To address the issue, the University of Missouri System has developed conflict of interest policies (see Collected Rules & Regulations 330.015 and 420.030). Per the policy, all employees are required to submit an Outside Interest Disclosure Form.
A case that often arises in technology transfer regarding potential conflict of interest is when the University is negotiating a license with a faculty startup company. In such situations, the faculty members involved would need to disclose via eCompliance before the license could be signed. The disclosure must also be available for public review for 10 days.
What happens if I don't disclose potential Conflicts of Interest?
The University of Missouri policy requires disclosure of outside interests annually and/or whenever an outside interest arises or changes. Violation of this policy constitutes a breach of the employment contract and may lead to disciplinary action. In some cases, the failure to disclose and manage conflicts of interest is also a violation of state and federal regulations and mandated sanctions apply. Furthermore, failing to file an Outside Interest Disclosure Form can result in slowing down grant proposals and other approval processes at the University.
If you have any questions related to Conflict of Interest, please contact Danielle Hunter 314-516-5972.