Financial Conflict of Interest

Introduction: The federal Department of Health and Human Services has developed regulations (42 CFR Part 50 Subpart F and 45 CFR Part 94) on Promoting Objectivity in Research. These regulations describe the actions an individual and an organization must take to promote objectivity in Public Health Service (PHS)-funded research. The regulations apply to all PHS (e.g., National Institutes of Health [NIH])-funded grants, cooperative agreements, and research contracts.  


Scope: This policy applies to all personnel, including full-time, part-time, temporary, and contract employees of WINTHROP UNIVERSITY, who are participating in, or planning to participate in, the design, conduct, or reporting of Public Health Service funded research and research proposals. 

Federally-supported research projects involving subawardees or contractors (collectively subrecipients) of WINTHROP UNIVERSITY are required to provide written assurance that a Financial Conflict of Interest (FCOI) policy is in effect that is compliant with  all  applicable  federal regulations, or that the subrecipient  will  conform  to  and  abide  by WINTHROP UNIVERSITY’s FCOI policy and procedures. Consistent with PHS regulations, this policy will be made available via a publicly accessible website. All WINTHROP UNIVERSITY Investigators 
(that  is, individuals  who, regardless  of  position  or  title,  are  responsible  for the design, conduct, or reporting of PHS supported research, and Investigators seeking PHS research support) shall be informed where this policy and relevant reporting requirements may be accessed via the WINTHROP UNIVERSITY Policy Repository website. The purpose of this policy is to prevent potential bias resulting from any FCOI by individuals who have influence in the allocations and use of public funding in the conduct of research. 

This policy applies to research and initiatives funded by PHS grants wherein WINTHROP UNIVERSITY is the recipient of such funds and it implements the regulatory requirements for WINTHROP UNIVERSITY. This policy aligns to the requirements within regulation 42 CFR Part 50- Subpart F (FCOI regulation) with the goal of promoting objectivity and transparency in research.

Financial Conflict of Interest Full Policy (PDF - 102KB)