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Financial Conflict of Interest, FCOI

This “Financial Conflict of Interest on Federal Grants Policy” was crafted in response to federal regulations that require that all investigators disclose any potential financial conflict of interest to the university prior to undertaking federally funded research. This policy is applicable to all federally funded sponsored project activity at Albany State University (ASU). It was designed to promote objectivity in research by establishing standards that provide a reasonable expectation that the design, conduct, and reporting of research funded by federal grants or cooperative agreements will be free from bias resulting from investigator financial conflicts of interest.


Policy - Financial Conflict of Interest, FCOI (if unable to open the policy with the browser Explorer use Mozilla Firefox)


Required Training


Investigators on projects funded with federal dollars are required to complete financial conflict of interest training prior to the release of grant funds. In the case of current, federally funded projects the training will need to be completed prior to the release of any additional funds. The training is provided through the Collaborative Institutional Training Initiative (CITI).

To access the training module, proceed with the following steps:

  1. Go to the Collaborative Institutional Training Initiative website (www.citiprogram.org).
  2. For new users, click on, “Register Here.”
  3. Select your institution from the Participating Institutions drop-down list (Albany State University).
  4. Enter your personal member information and proceed to the next page.
  5. On the Select Curriculum page, choose Financial Conflict of Interest.
  6. Click on “Enter” under “Status” to begin your training module.
  7. If you are already a registered CITI user, select “add a course or update my learner groups” link from the Main Menu and select the appropriate question/option to enroll in the course.
  8. The training takes approximately thirty minutes but, you can start and stop, and return later.
  9. Once your training has been successfully completed, a completion report will be archived which will be accessible to the ORSP research compliance staff.


Required and Annual Disclosures


Investigators and Senior/Key Personnel must submit FCOI disclosures annually or at the time of submission of a grant to a federal agency. Annual submissions will be required in August of each year. 

All submitted FCOI forms will be reviewed by the Associate Vice President of ORSP and/or their designee (and if a conflict is noted, by the Financial Conflict of Interest Committee).

Any newly discovered or acquired significant financial interest (e.g., through purchase, marriage, or inheritance) must be disclosed by submitting a revised FCOI form to ORSP within thirty days of that change.


Form - FCOI Disclosure Statement