An Investigator must disclose to the institution all significant financial interests (SFIs) (and those of his/her spouse and dependent children) RELATED TO HIS/HER INSTITUTIONAL RESPONSIBILITIES at the time the research proposal is submitted to the grant awarding agency

1. Project Director/Principal Investigator (PD/PI) is responsible for his/her own SFI disclosure and determines who meets the definition of “Investigator” on their project
   • The PD/PI identifies all other individuals, regardless of title or position, who he/she identifies as responsible for the design, conduct, or reporting of research or proposed for such funding
   • It is the PD/PI’s responsibility, in conjunction with department assistance, to notify and secure disclosures from the identified Investigators
2. The designated Investigators complete the Significant Financial Interests Form (SFIF)
   • Project-based form – one form for each project for each designated investigator (completed form may be duplicated for different projects)
   • If the investigator has no SFIs, no further action is required
   • If the Investigator has one or more SFIs, he/she completes the SFI Attachment (1 per SFI entity)
3. The identified Investigators send the completed SFIF and, if applicable, the SFI attachments to ORA (hscora@ouhsc.edu)
   • All disclosures must be received by ORA before an application can be approved for submission
4. A copy of the SFIF is forwarded to the Vice President for Research (OUHSC Institutional Official) for review
   • Institutional Official evaluates every PHS-research-related SFI in the context of each PHS project to determine if the interest creates a Financial Conflict of Interest (FCOI)
   • May involve the investigator in that review process
5. If the Institutional Official determines there is no FCOI, the process is complete
6. If the Institutional Official determines there is an FCOI, then he/she will work with the investigator to create a FCOI management plan.
   • Within 60 days of receipt of disclosure
   • Application may be submitted without management plan as long as all SFIs for all designated Investigators have been disclosed
   • The original disclosure along with the decision is kept in the proposal file and will be used to verify at the Just-in-Time (JIT) and award stages
7. The Institutional Official reports provides details of FCOI and management plan to funding agency