At proposal submission and award the PI needs to declare conflicts of interest and nepotism. If nepotism is involved then the PI needs to submit nepotism forms from the Provost office http://www.ou.edu/provost/memos To determine if you have a conflict of interest refer to http://www.ou.edu/provost/memos Faculty Compliance Issues and Section 5.10 of the Faculty Handbook
For proposal routing the following items are needed, as applicable
COI Management Plan
The COI Management Plan should contain the following:
Public Health Service (PHS) Conflict of Interest (FCOI) disclosure and training is needed on all proposals/awards being submitted to or funded from a PHS source. The disclosure form is needed at routing by all PI and CoPI on the proposal. This is a separate requirement from COI (above) and does not negate the probable need to also do the University COI process.
Flow of disclosure, training, and additional information follows.
According to the federal requirements, all PHS-funded “Investigators” at OU must complete the online FCOI training which is available here: https://www.citiprogram.org/. Successful completion of the training is required prior to the expenditure of funds on any newly-funded projects, including noncompeting continuation awards. This applies to all PHS-sponsored research projects as of August 24, 2012. Training must be completed at least every four years. Current PHS awards are not subject to these new requirements until the noncompeting continuation is awarded.
New users to the CITI program must create an account. The same CITI account can be used for both the FCOI requirement and OU's IRB training requirement.
Investigator, for the purposes of this policy, means the Principal Investigator and any person listed by the Principal Investigator as responsible for the design, conduct, or reporting of their sponsored program(s). These individuals are listed at the time of proposal submission.
Normally, all senior research personnel should be listed as “Investigators.” All of the following should be considered, to the extent they are responsible for the design, conduct, or reporting of the sponsored program: professorial faculty, research associates, emeritus faculty, research collaborators, visiting scientists, post-docs, GRAs, or students.
PHS means the Public Health Service of the U.S. Department of Health and Human Services, and any components of the PHS to which the authority of the PHS may be delegated. The components of the PHS include, but are not limited to:
Other agencies may follow PHS regulations, these include (but aren’t limited to) - Alliance for Lupus Research, Alpha-1 Foundation, American Asthma Foundations, American Cancer Society, American Heart Association, American Lung Association, Arthritis Foundation, CurePSP, JDRF - Juvenile Diabetes Research Foundation, Lupus Foundation of America, Patient-Centered Outcomes Research Institute (PCORI), and Susan G. Komen Foundation
Inquiries about the NIH FCOI regulation for grants and cooperative agreements may be directed to: VPRFCOI@ou.edu