Establish consistent requirements for disclosure of FCOI

Since the implementation of the PHS requirements for disclosure of potential financial conflicts of interest for all key personnel at the time of proposal, this has been one of the most burdensome requirements for Faculty and staff at the University of Chicago. Last year alone we were required to obtain over 5,000 disclosures of financial interests before PHS proposals could be submitted, while only 115 of those disclosures resulted in the identification of a potential financial conflict of interest requiring some type of management by the institution. The cause of this is two-fold; first PHS requires the disclosure at the time of proposal when roughly 80% of proposals submitted are never awarded. Second the definition of what constitutes a “Significant Financial Interest” is too broad requiring far more reporting than is necessary to identify actual conflicts of interest. Additionally, there is no standard set of requirements for identification and reporting of financial conflicts of interest across agencies. Some, such as NSF, have very manageable requirements focused on the institutions ability to manage a potential conflict once an award has been made. Others, such as the PHS requirement is extremely burdensome (for the reasons described above). Other Agencies such as EPA are just now establishing new requirements which are complicated and burdensome to recipients. The obvious danger in making this recommendation is that one of the more burdensome processes will be selected to standardize from. If this problem is to be corrected, the recipient community needs to have significant and meaningful input into the solution. After all, protection of the integrity of our researchers and the institution is extremely important to all of us.