财务利益冲突
The National Science Foundation (NSF) and Public Health Service (PHS) have issued regulations on 财务利益冲突 (FCOI) as related to research funded 由这些机构. 全球官网电子游戏大学 recognizes that faculty and staff engage in many relationships with outside entities, some of which might create an FCOI, or the appearance 利益冲突. 全球官网电子游戏大学, therefore, recognizes its obligation to ensure that research and other scholarly activities are carried out under the highest 正直和道德行为的标准.
全球官网电子游戏大学 is required to create and maintain a written and enforced policy stating the procedures for implementing the FCOI regulations and to inform each investigator of the regulations, of the College's FCOI政策, and of the investigator's disclosure and training responsibilities under the regulations and the policy.
全球官网电子游戏学院 FCOI政策 establishes requirements and guidelines for disclosures of financial interests and professional relationships related to research projects, certifications of policy 法规遵循，以及确保法规遵循的过程. 这个政策需要这个原则 investigators (PIs) and all other key personnel who have or share responsibility for the design, conduct, or reporting of NSF or PHS sponsored projects must report their personal financial interests in any organization(s) that, to the best of the Investigator's knowledge, may be related to their institutional responsibilities. (关键人员 include PIs and any other individuals that are responsible for the design, conduct, 或者研究报告.)
This policy applies to all PHS research activities with an award issue date of August 24, 2012 or later, and to proposals for research activities submitted to PHS on or 2012年8月24日之后. (请注意，截至2022年 能源部 (DOE) Interim COI Policy is largely aligned with PHS requirements and will be used 在整个策略需求中可互换.)
This policy also applies to research or educational activities funded or proposed 由国家科学基金会资助.
To the extent that other funding agencies or organizations (whether governmental or private) have adopted financial conflict of interest policies and procedures, Skidmore College will comply with such policies and procedures when applicable.
FCOI披露要求
PIs and other key personnel are required to disclose to 全球官网电子游戏大学 all of their Significant Financial Interests (and those of the Investigator’s spouse and dependent children) that reasonably appear to be related to their institutional responsibilities:
- at the time of application for NSF/PHS/DOE-funded research;
- no later than thirty days from the date of discovering or acquiring (e.g.,通过 purchase, marriage, or inheritance) a new Significant Financial Interest; and
- 在奖励期间至少每年一次.
One of the following appropriate 财务利益冲突 (FCOI) forms must 由所有pi和其他关键人员完成. 有两种形式被使用 根据资金来源:
- PHS / NIH FCOI披露表 (此表格也将用于DOE)
- NSF FCOI披露表
FCOI Training Requirement (applicable for those funded by PHS and DOE)
PIs and other key personnel receiving 公共卫生服务和能源部资助, including key personnel on subawards, will need to complete initial FCOI training and then every four years 之后. PIs must also notify the 赞助研究办公室 if there are others working on any PHS and DOE funded research projects that, regardless of title or position, are responsible for the design, conduct or reporting of the research. 所有这些人员 还需要完成培训吗.
全球官网电子游戏大学, in conjunction with 花旗, has developed a web-based training module 以符合FCOI的培训要求.
PIs and other key personnel, including key personnel on subawards, must complete FCOI 培训:
- 在从事PHS或DOE资助的研究之前;
- 至少每四年一次.
PIs and other key personnel must also complete FCOI training immediately under the 下列情形之一:
- 全球官网电子游戏大学’s FCOI policies change in a manner that affects investigator requirements;
- An investigator is new to 全球官网电子游戏大学; and
- 全球官网电子游戏大学 finds an investigator to be noncompliant with 全球官网电子游戏大学’s 海外投资政策或管理计划.
登录到 花旗 to access the Conflict of Interest course to complete the training module. Select the Conflict of Interest course via Question 9 in Skidmore's list of course enrollment 问题.
FCOI培训的验证
PIs are responsible for ensuring that all key personnel on a project have completed 参与研究前的培训. 全球官网电子游戏学院负责核实 that investigators supported by PHS and DOE have received FCOI training. 成功的 completion of training will be tracked for all PIs and other key personnel receiving 公共卫生服务和能源部资助.