Conflicts of Interest (COIs) Disclosures & Management

University Policy

Institutions that apply for or receive Public Health Service (PHS) funding must adhere to Financial Conflict of Interest (FCOI) regulations. Northeastern University’s policies: (1) Financial Conflict of Interest (FCOI) Related to Research and (2) Policy on Conflict of Interest and Commitment (COIC) are designed to help Northeastern Faculty members engaged in research comply with the latest PHS regulations. This page provides the necessary information to faculty members on mitigating risks.

Faculty members engaged in research will need to adhere to two policies, in addition to the FCOI Policy referenced above, the University also has a broader Conflict of Commitment and Interest Policy. This Conflict of Interest and Commitment Policy focuses on conflicts of interest that may arise when there is a divergence between an individual’s private interests and his or her professional obligations to the University such that an independent observer might reasonably question whether the individual’s professional actions or decisions are determined by considerations of personal gain, financial or otherwise. A conflict of interest depends on the situation, and not on the character or actions of the individual. The Faculty Handbook (specifically, section 5, Faculty Involvement in Outside Entities which Have Relations with Northeastern) contains additional provisions related to Conflict of Commitment and Interest.

A financial conflict of interest (FCOI) as detailed in the PHS regulations and covered in the FCOI Policy, is a financial interest held by an Investigator that could directly and significantly affect the design, conduct, or reporting of research.

Since there are some nuances between the PHS FCOI regulations and Northeastern’s Conflict of Commitment and Interest Policy, PHS funded Investigators, and Investigators funded by agencies and foundations that have elected to follow FCOI guidelines, must adhere to the FCOI Policy.

Related Policies & Guidance

Additional Resources

Training

The University subscribes to the CITI Training program platform to provides researchers the required FCOI related training, per their individual PHS award. Most PHS funded awards require that researchers receive FCOI training every 3 years. The CITI program COI course satisfies this requirement, Financial Conflicts of Interest: Overview, Investigator Responsibilities, and COI Rules (COI-Basic) (ID 15070).

Reporting

For more information about reporting conflicts and potential conflicts, please visit the University Compliance Dept. webpage.

Main Point(s) of Contact

For questions regarding the PHS FCOI regulations and the University’s implementation thereof, contact the FCOI team at FCOI@northeastern.edu.

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