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Financial Conflict of Interest in Research Policy (FCOIr):
Documenting Objectivity in Science

Completion of the COI certification administered by the General Counsel's Office at Miami does not meet the federal requirements for research activities. The issues, reporting thresholds, and management differ. The University wide certification addresses state law and addresses contracting and purchasing issues whereas the FCOI research certification is intended to support the ideal goal of scientific objectivity.

Faculty, staff, sudents and collaborators must comply with Miami Policies to minimize perceptions that research findings may have been influenced by external sources. When relationships with an external entity are of a financial nature, such perceived or real Financial Conflict of Interest in Research (FCOIr) must be addressed. When research is federally funded, Miami is contractually obligated to comply with the policies for FCOIr (2 CFR 200.112) which directs funding agencies to have established policies). The policy at Miami unifies the policies of NIH and NSF to meet the requirements of both. Conflicts are common and not all warrant management, therefore the policies define types of interests, relationships, and monetary thresholds that need to be disclosed and potentially managed. FCOIr issues are discussed during RCR workshops.

There are four basic steps to addressing potential concerns regarding FCOIr:

1. Understanding the nature of Significant Financial Interests (SFI's) and confidentially disclosing those that exist to Miami administration. Absent reportable SFI's for researchers and immediate family members, the researchers assure through an annual online certification that they have no known external SFI's. The online questionnaire (google form linked above and below) requires logging in using Miami UniqueID to establish a means of certifying identity. Since there is a regulatory requirement for researchers to understand the various aspects of FCOIr, the questionnaire is used not only to respond to simple questions, but to provide the information and certify that researchers have completed the educational requirement.

2. Research team members must also understand that if an SFI develops after the most recent certification, it must be disclosed within 90 days. If no SFI's are indicated in the annual certification or develop, no further action is required.

3. If SFI's are disclosed, the Director of Research Ethics and Integrity or the Vice President for Research and Innovation determines and confidentially documents whether the SFI constitutes a Financial Conflict of Interest that may be perceived to influence the research (FCOIr).

4. If an FCOIr is identified, a management plan is developed to avoid the potential issues raised by FCOIr in the specific project. The table below describes SFI's that must be disclosed and managed if not explicitly excluded (column 2). SFI's from external entities and potential FCOIr's are not prohibited, but disclosure, documentation, and management may be required.

If reportable SFI's develop at any time since the last annual certification, the researchers must re-certify and contact the Research Ethics and Integrity Office or Vice president for Research within 14 days. A report and management plan must be submitted to the agency for NIH funded research within 60 days of grant receipt or the development of a reportable SFI.

Failure to disclose SFI's that meet reporting requirements constitutes potential Research Misconduct and will be handled as such to include investigation and the full range of possible sanctions. 

  Nature of SFI

  Excluded Interests
(Does not require disclosure or management)

Compensation and/or other payments for service over $5000

Compensation received less than $5,000, as well as any
compensation received for lectures, seminars, teaching engagements, or service on advisory committees or review panels relating to federal, state, or local government agencies, an institution of higher education or research institute that is affiliated with an institution of higher education, and compensation received from MU funds.
Sponsored or reimbursed travel valued at over $3000 Travel administered through MU funds, and travel reimbursed
or sponsored by a federal, state, or local government agency, an institution of higher education, an academic teaching hospital, a medical center, or a research institute that is affiliated with an institution of higher education.

Equity interests in a publicly-traded entity (stock) with a value of over $5000

Interests in publicly-traded entities valued at less than
$5,000 as well as interests in any entity through personal retirement accounts and mutual funds

Any equity interest in a non-publicly-traded entity with a value of over $1000

Interests in any entity through personal retirement accounts
and mutual funds

Compensation for intellectual property with a value of over $1000

Royalties received from MU funds, and unlicensed intellectual
property that does not generate income



A PDF of the survey form is posted here.

Please do not submit this example, use the link to the secured online survey above.


Please contact the Research and Innovation Office if you have questions about this web site: 513-529-3600
    or email Neal Sullivan at or Jennifer Sutton at

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