US Financial Conflict of Interest

This page outlines what UBC requires of all Investigators applying for, holding, or working on studies that must comply with the US Public Health Service Financial Conflict of Interest Regulations (PHS FCOI Regulations).  

View the PHS FCOI Regulations

View the UBC Directive Upated May 26, 2023 

The PHS FCOI Regulations establish Investigator reporting AND training requirements and apply to all PHS funded research including NIH funded research. These Regulations have also been adopted by other organizations. Please see the List of Granting Agencies requiring compliance with the Regulations. This list is provided for your convenience and may not be complete so please check with your funding agency if you are unsure whether compliance is required.

A. Before a grant application is submitted

The UBC PI must ensure the following steps are completed:

  1. Provide a List of Investigators, including UBC Investigators as well as any Subrecipient (SR) and unpaid External Investigators involved with the study.
    Note 1 | If the PI is the only investigator working on the UBC portion of the study, a List of Investigators form is not required.
    Note 2 | If UBC is a subrecipient, the list should only include those Investigators who will be working on the UBC portion of the study.
  2. All UBC Investigators have submitted a SFI Disclosure (Form 1).
  3. If the List of Investigators includes sub recipient (SR) and/or unpaid External Investigators, an authorized official of the SR/External institution has signed and submitted the Subrecipient/External Investigator Institutional Declaration (Form 2).
    Note 3 | If a SR/External Investigator opts to follow UBC's US FCOI Policy, they are required to complete the Subrecipient SFI Disclosure (Form 3).

B. Once a grant has been awarded, but before funds are released

The UBC PI must ensure all Investigators following UBC's US FCOI Policy have completed two training modules:

  1. NIH FCOI tutorial (approximately 45 minutes)
    Investigators must submit the Certificate of Completion to UBC’s Designated Institutional Official ( and keep a copy for their records.
  2. UBC US FCOI tutorial (approximately 20 minutes)
    The presentation provides instructions for demonstrating completion of the training.

A certificate of completion will be automatically generated and sent to when you complete the tutorial.

Renewals for training modules are required every 4 years. You will receive an automated reminder to renew your tutorials.

Subrecipients/External Investigators NOT following UBC's US FCOI Policy

Where a Subrecipient Investigator who is following their institution’s Financial Conflict of Interest policy is found to have a FCOI, the Subrecipient Institution must report the FCOI to UBC as follows: before awarded funds are released; annually; and within 45 days of a new FCOI being identified. Please contact for further instructions.

These procedures are conditions of receiving funding as required by the US PHS Financial Conflict of Interest Regulations. Failure to comply could seriously compromise UBC’s ability to continue to receive US PHS funding.

C.    Resources

UBC List of Investigators Form
List of Investigators 

UBC Significant Financial Interest Disclosure
Form 1   Form 1 Information Sheet

Subrecipient/External Investigator Institutional Declaration
Form 2  Form 2 Information Sheet

Subrecipient/External Investigator Significant Financial Interest Disclosure
Form 3  Form 3 Information Sheet