Policy & Procedures for Financial Conflict of Interest (FCOI)

The University of Maine’s Policies and Procedures for Financial Disclosures and Conflicts of Interest in Extramurally Sponsored Activities (Word), applies to all University employees and students who serve as investigators on proposals submitted to external sponsors. The policy applies equally to UMaine investigators, and investigators at other University of Maine System (UMS) campuses (‘UMS investigators’) who wish to submit through, or collaborate with UMaine on an extramural funding request.

Procedures

An overview of the full process can be found in the Financial Conflict of Interest (FCOI) Flowchart:

FCOI Flowchart (Diagram) (PDF)

Investigator Actions

Key steps required by investigators during the FCOI process are outlined below.

  1. Prior to submitting a request for extramural funding, each Investigator (PI or Co-PI) named in a proposal must successfully complete the Collaborative Institutional Training Initiative (CITI) FCOI training and certify whether they have a significant financial interest related to the proposed activity (This certification is generally completed in Proposal Automated Routing System [PARS]).
  2. Any Investigator having such an interest must complete a Significant Financial Interest Disclosure Form (PDF).
  3. In the proposal text, or in an attachment to the proposal, the Investigator must describe their significant financial interest or potential conflict of interest (see Example COI [Conflict of Interest] Narrative).
  4. Steps to manage or eliminate conflicts of interest will be incorporated into a Conflict Resolution Plan approved by the Financial Disclosure Review Committee (FDRC). Each Investigator must certify that they will adhere to all terms and conditions of a Conflict Resolution Plan prior to the University’s acceptance of an award.
  5. The investigator will be required to periodically reports/update information.

Note: Individuals not listed as investigators in proposals who later assume such roles through hiring, promotion, or other means are required to complete CITI FCOI training, complete and submit either a PI Certification Statement (PDF) (external link) or a Co-PI Certification Statement (PDF) (external link) and make any applicable disclosures prior to commencing work on the project.

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