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Who Must Report Financial Conflicts of Interest (fCOI)?

Guidance for Determining Applicability of the fCOI Policy Based on Project Roles

All university research personnel, including key personnel, are required to report their external commitments and financial interests annually and on an event required basis for themselves and their spouse/same-sex partner and children (hereinafter defined as "family"). The unit is responsible for identifying individuals responsible for the direct administration of research and any newly appointed individuals who participate in research.

Research Personnel is defined as any individual responsible for the design, conduct, or reporting of research, including key personnel, as well as those responsible for the direct administration of research.

Key Personnel is defined as any individuals responsible for the design, conduct, or reporting of a research study, including:

  • For sponsored research: (1) Principal investigators, co-principal investigators, co-investigators, and any other individual named in a sponsored project budget, narrative, key personnel list, by CV attachment, or noted anywhere else by name in a proposal or award; and (2) Anyone who during the course of a sponsored project assumes a role synonymous with the roles above.
  • For non-sponsored research: Those whose role on the research project is synonymous with the roles described above.
  • For IRB protocols: Non-student principal investigators and co-investigators.

Direct Administration of Research is defined as oversight or decision-making impacting research that includes: selection of vendors, determining the allocation of funds, sponsor negotiations for the research project, protocol review and approval, or managing resulting intellectual property and licensing opportunities.


  1. For IRB protocols, "Research Personnel" excludes Undergraduate students who may be Principal Investigators and co-Investigators, named on protocols.
  2. For current, active awards or IRB protocols: Research personnel who are required to report per this policy, but were not previously required to report, must report at the time of award renewal or protocol continuation.