Columbia University Medical College

Conflict of Interest and Research

PHS COI Regulations

The Department of Health and Human Services has a new financial conflict of interest regulation - Responsibility of Applicants for Promoting Objectivity in Research for which Public Health Service Funding is Sought and Responsible Prospective Contractor. The regulation, which took effect on August 24, 2012, governs research sponsored by NIH, CDC, AHRQ, and other Public Health Service (PHS) agencies and applies to all investigators on new awards, new proposals, non-competing renewals, and no cost extensions received or submitted on or after that date.  The regulation includes significant new requirements for all PHS investigators, including:

  • Broader disclosure requirements of all financial interests that relate to an individual's institutional responsibilities, including compensation from non-profit entities and sponsored travel
  • Mandatory Training: All PHS researchers must complete training in Financial Conflicts of Interest in Research.  Rascal course TC1450 - Financial Conflicts of Interest for PHS Researchers satisfies the requirement.  Alternatively, Rascal course TC0087 - Human Subjects Protection Training was updated to include the PHS-required training; human subjects researchers who completed TC0087 (Basic or Refresher) on or after July 16, 2013, have satisfied the training requirement.

  • A lower threshold of $5,000 for "significant financial interests"

Below are resources about the new regulation for PHS-funded researchers.

University Resources 

Frequently Asked Questions for PHS Investigators

Disclosure Checklist

Policy on Financial Conflicts of Interest and Research (revised effective August 24, 2012)

Appendix 2: Compliance with Revised Public Health Service Regulations 

Rascal Training on Financial Conflicts of Interest and Research for PHS Researchers

Rascal COI Disclosure Form

PowerPoint Presentation on Financial Conflicts of Interest and Research: 2012 Developments

External Resources

NIH Frequently Asked Questions

PHS FCOI Regulation