University of São Paulo - Brazil

Financial Conflict of Interest (PHS/NIH FCOI)

Public Health Service/National Institutes of Health – Financial Conflict of Interest (PHS/NIH FCOI)

Institutions that apply for or receive Public Health Service (PHS) funding must adhere to Financial Conflict of Interest (FCOI) regulations as promulgated at 42 CR 50 subpart F and took effect August 24, 2012.

A summary of the PHS FCOI Policy is as follows:
– all Investigators must disclose any Significant Financial Interest (SFI) with respect to their Institutional Responsibilities to Research Provost’s Office (PRP) that will determine whether such interest constitutes a Financial Conflict of Interest (FCOI)
– where an SFI is determined to be an FCOI, a management plan will be drawn up to help manage, reduce or eliminate the FCOI
– a disclosure of the FCOI and management plan must be submitted to the PHS-funder
– adherence to the management plan must be monitored
– all PHS-funded Investigators are required to take training on conflicts of interest
– annual (and in some circumstances more regular) reporting of FCOIs to the PHS-funder is required
– before any expenditure of PHS funds, information concerning any disclosed SFI which has been determined to be an FCOI relating to PHS-funded research, must be made publicly accessible by written response within 5 working days of request.

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

For further information, access