Financial Conflicts of Interest and Conflicts of Commitment

Training and the FCoI/CoC disclosure is required for all covered individuals associated with a project supported by a federal grant. These covered individuals include: subrecipient, undergraduate assistant, technician, graduate assistant, research assistant, research associate, postdoctoral fellow, senior personnel, principal investigator, and co-principal investigator.

The FCoI/CoC Disclosure is required prior to submitting a federal grant.
The CITI Training is required prior to opening of award.

The CITI training COI-Public Health Service course is valid for four years for most (two years for some).

DOE has noted that “research security training developed for compliance with CHIPs and Science Act of 2022 addresses COIs and COCs and therefore could be relied upon to meet this requirement.” CITI Program’s Research Security series includes the NSF’s Research Security Training, the NSF SECURE Center’s Consolidated Training Module (CTM), and the NSF SECURE Center’s Annual/Refresher Training Module (ARTM).

An FCoI/CoC disclosure is required for every federal grant submission and at least annually or upon new items to disclose.