UMSL encourages faculty and staff collaboration with teaching, government agencies, and industry. External relationships establish valuable connections, enrich research, expand career opportunities for students, and provide a mechanism for the translation of University developed intellectual property into commercial ventures. However, this dual relationship can lead to inherent conflicts of interest. The Collected Rule 330.015 for Conflict of Interest requires employees complete a disclosure of outside interests at least annually and as any changes or new acquisitions arise.
Learn more about what is considered an outside interest that would be considered reportable. The list is not all inclusive and there may be differences that change the outcome. Please contact the Compliance Manager at 516-5972, if you are unsure if an outside interest is reportable.
To submit, log into eCompliance using your SSO or email address and password.
See the user guide for step by step submission instructions.
See the user guide for step by step submission instructions for updating your disclosure.
The Outside Interest Disclosure Review Flowchart illustrates what happens following the submission of disclosures in eCompliance.
The FCOI guidelines and forms discussed here are applicable to all research funding by the Public Health Service (PHS) and the National Science Foundation (NSF). See a list of PHS agencies in the right-hand column of this page.
In response to increased public scrutiny and concern about conflicts of interest at research institutions, the Public Health Service (PHS) has redrafted its conflict of interest regulations ( 42 CFR Part 50 Subpart F and 45 CFR Part 94). This increased public scrutiny is a result of both the increase in relationships between researchers and industry and the increased rate at which research is brought from the bench to the market place. Strengthening the existing regulation on managing financial conflicts of interest is key to assuring the public that the institutions PHS supports are taking a rigorous approach to managing the essential relationships between the government, federally funded research institutions, and the private sector. These revised regulations were effective as of August 24, 2012.
PHS has provided the following guide for determining who is an investigator.
§50.603 Definitions: Investigator means the project director or principal Investigator and any other person, regardless of title or position, who is responsible for the design, conduct, or reporting of research funded by the PHS, or proposed for such funding, which may include, for example, collaborators or consultants.
PHS comments about the Investigator definition:
“…the definition of “investigator” has been revised in the final rule to emphasize that Institutions should consider the roles of those involved in research and the degree of independence with which those individuals work.”
“…we note that the definition refers to the function of the individual on the PHS-funded project; i.e. his/her responsibility for the design, conduct or reporting of the PHS-funded research, and not to his/her title or the amount and /or source of remuneration.” This broad definition may include post-doctoral associates, graduate students, etc.
Prior to Submission for all Federal and Federal Flow-Through Funding from PHS and NSF:
STEP 1: CITI Training, Conflict of Interest Mini Course
Required for all investigators identified on the UMSL Investigator Form. Training is required prior to submission of the proposal and every four (4) years thereafter. Log into eCompliance, select the Conflict of Interest module, then click on Conflict of Interest Training on the right side of the screen. After clicking, there will be instructions available for how to select the correct training.
STEP 2: Submit Outside Interest Disclosure in eCompliance
STEP 3: UMSL Investigator Form
Must be included with the your signature page and PeopleSoft submission pages. NOTE: The ORA will ask you to review the Investigator Form at time of award and update the form whenever changes occur throughout the life of the project. UMSL Investigator Form.
Prior to Submission for Funding from Non-Federal and Other Sponsors Not Adopting the New FCOI Regulations:
STEP 1: Submit Outside Interest Disclosure in eCompliance
Required for all investigators identified on the UMSL Investigator Form.
Additional Information:
Employee interactions with the private sector carry potential for conflict of interest, or the perception of such conflicts. To address the issue, the University of Missouri System has developed conflict of interest policies (see Collected Rules & Regulations 330.015 and 420.030). Per the policy, all employees are required to submit an Outside Interest Disclosure Form.
A case that often arises in technology transfer regarding potential conflict of interest is when the University is negotiating a license with a faculty startup company. In such situations, the faculty members involved would need to disclose via eCompliance before the license could be signed. The disclosure must also be available for public review for 10 days.
The University of Missouri policy requires disclosure of outside interests annually and/or whenever an outside interest arises or changes. Violation of this policy constitutes a breach of the employment contract and may lead to disciplinary action. In some cases, the failure to disclose and manage conflicts of interest is also a violation of state and federal regulations and mandated sanctions apply. Furthermore, failing to file an Outside Interest Disclosure Form can result in slowing down grant proposals and other approval processes at the University.
