Financial Conflicts of Interest
The Financial Conflicts of Interest (FCOI) Policy at Stevens Institute of Technology in research serves to uphold the integrity and impartiality of research at the institution and its faculty and staff members. This policy is crafted to facilitate the disclosure, identification and management or resolution of circumstances where personal or familial interests could potentially compromise, or give the appearance of compromising, the objectivity of faculty and staff in their roles as educators, researchers, or administrators. By implementing an effective financial conflict of interest policy, Stevens Institute of Technology aims to protect the professional standing and work of its academic community while ensuring full compliance with federal and other regulatory mandates concerning financial conflicts of interest.
What is a Financial Conflict of Interest?
A Financial Conflict of Interest in research arises when an Investigator's professional judgment in designing, conducting, or reporting research is influenced or could be perceived as influenced by a Significant Financial Interest.
Who is an investigator?
Investigator refers to the project director or principal investigator and any other person, regardless of title or position, responsible for the design, conduct, or reporting of research, including research proposed for funding. Investigators may include students, consultants, and contractors. Stevens’ Investigators include faculty, staff, and students explicitly named in sponsored research applications, proposals, and budgets, and also includes key personnel identified in progress reports that Stevens submits to sponsors.
The Principal Investigator or Project Director must consider each individual’s role and degree of independence in carrying out the work and determine who is responsible for the design, conduct, or reporting of the research.
Department of Energy (DOE) program offices have the discretion to expand the definition to also include any person who participates in the purpose, design, conduct, or reporting of a project funded by DOE or proposed for funding by DOE. Such expansion will be specified in the applicable funding opportunity announcement and/or terms and conditions of the financial assistance award.
What are my responsibilities?
Ensure compliance with the Stevens' policy on financial conflicts of interest in research, including understanding the definition of Significant Financial Interest (SFI) and its application to your role.
Promptly disclose all SFIs, including those of a spouse or dependent child, that reasonably relate to your institutional responsibilities. Comply with any FCOI management or mitigation plans if applicable.
Submit a financial disclosure through Stevens' WorkDay:
Every 12 months
Within 30 days of acquiring or discovering a new SFI
Within 30 days of any reimbursed or sponsored travel
Conduct FCOI training every 4 years and under the following circumstances:
Within 60 days of any changes to the University's FCOI policy that impact investigator requirements
When an investigator is new to the University
Upon the University's discovery that an investigator is not in compliance with the FCOI policy or an applicable management plan
Updates to Policy on Financial Conflicts of Interest
Immediate Actions for Investigators
Read and Comply with the Financial Conflict of Interest in Research Policy
The Stevens Policy on Financial Conflicts of Interest in Research requires Investigators to review the policy and disclose any Significant Financial Interests (SFI) at least annually that reasonably appear to be related to their Institutional Responsibilities.
Please note that the Policy on Financial Conflicts of Interest in Research operates in addition to Stevens’ university-wide Conflict of Interest Policy (located in the Policy Library) and does not replace or supersede the university-wide Conflict of Interest Policy or any other process at Stevens. Stevens Investigators must comply with the Policy on Financial Conflicts of Interest in Research in addition to the university-wide Conflict of Interest Policy.
Complete and Certify the FCOI Disclosure Form in Workday
Stevens’ Investigators need to complete the Financial Conflict of Interest Disclosure Form in the Stevens Workday system. You will have a FCOI Disclosure task delivered to your Workday inbox on March 28th, 2024. The form must be completed no later than April 12th, 2024.
For details or assistance relating to Workday, please refer to this article on How to Complete the Financial Conflict of Interest Form.
Complete and Submit Required Training
In addition to the above, Investigators must participate in training about the Policy on Financial Conflicts of Interest in Research before engaging in research activity and at least every four years thereafter, and consistent with the terms of the Policy.
The required training is accessible online through the Collaborative Institutional Training Initiative (CITI). On the CITI website, you must complete the four modules under Conflicts of Interest:
Financial Conflicts of Interest: Overview, Investigator Responsibilities, and COI Rules (COI-Basic) (ID: 15070)
Institutional Responsibilities as They Affect Investigators (COI-Basic) (ID: 15072)
Conflicts of Commitment and Conscience (COI-Basic) (ID: 15073)
Conflicts of Interest Institution-Specific Policies (ID: 21375)
If you are new to CITI, please refer to the article on the CITI website relating to Guide to Getting Started. Please remember to affiliate your training with Stevens to ensure we receive notification upon completion.
FCOI Policies, Regulations and Guidance
Stevens FCOI Policy
Federal FCOI Regulations
Additional Information on PHS/NIH FCOI