FCOI Requirements

UB is dedicated to maintaining public trust in the integrity of our research related activities.

The identification and responsible management of financial conflicts of interest (FCOI) is crucially important both for safeguarding research objectivity and for compliance with federal regulations and university policies.

About the Requirement

The policy requires each funded investigator to submit a Disclosure Statement to his/her cognizant dean or vice president, annually, but no later than the following:

  • Submission of an application or prior to the release of grant funds, whichever comes first.
  • Submission of a human study protocol for review by an Institutional Review Board (IRB).
  • Within 30 days of discovering and/or acquiring significant financial interests or significant obligations that have not been previously disclosed.

If you plan to submit a grant proposal or are currently on an award, you have to complete a Financial Conflict of Interest Form to conform to UB’s Investigator Conflict of Interest policy, which  requires that any person who holds a University at Buffalo appointment and who is a Principal Investigator, Co-Investigator, or who is responsible for the design, conduct or reporting of sponsored  programs, projects, activities or services, must complete and submit an annual “Disclosure Statement of Significant Obligations, Significant Financial Interests, and Sponsored Travel.”

UB has a new on-line tool to better manage annual disclosures is available at www.coiriskmanager.com/sunybuffalo. This tool will better enable the submission, review and management of disclosures of financial interests, and will ensure UB’s compliance with revised federal regulations. Please note, if you have not done so, that you must also have to complete a CITI course regarding financial conflict of interest (see instructions below).

Steps for Selecting CITI COI Mini-Course

  1. Click: Go to CITI Program website.
    Note – if you are not currently registered for CITI you need to do so first, click “Register Here.”
  2. Select: "Add a course or update your learner groups" link for course selection.
  3. Click: "Yes" radio button under "Question 1 Would you like to take the Conflict of Interest mini-course?".
  4. Click: "Continue" button. This brings you back to the Main Menu.
  5. Click: "Enter" link for the Financial Conflicts of Interest

Once you complete and pass the CITI module you will receive a certificate. Please print out a copy for your files and one for the school’s files in the RAS Office (Kimball 818). 

Questions about the Investigator Disclosure Policy or the disclosure process should be directed to support@research.buffalo.edu

Please direct technical questions to support@research.buffalo.edu.

Thank you for completing the FCOI form and CITI course. If you have any questions, please contact the RAS office.

Conflict of Interest Review Process

This is to inform you of a change in the conflict of interest review process. Conflict of interest reviews for research studies involving human subjects will no longer be required by Sponsored Program Services at the time grant funding is received from the sponsor. Several units within the Office of the Vice President for Research and Economic Development have reviewed this process and concurred that it is redundant as conflict of interest reviews are already being carried out in conjunction with the IRB review process. Conflict of interest reviews will continue to be requested for sponsored research that does not involve human subjects. We hope this change will accelerate the availability of grant funds to investigators for use in their research. 

FCOI Officer, Office of Research Compliance