Procedure for Identifying and Managing Financial Conflicts of Interest (FCOI)

Office of Research and Sponsored Projects

II. Procedure for Identifying and Managing Financial Conflicts of Interest (FCOI)

Step 1: Submission of Financial Disclosure Form

TAMIU has a responsibility to identify and manage, reduce or eliminate conflicts of interest that may arise due to financial or other personal interests of an Investigator. Therefore, TAMIU requires Investigators to disclose financial interests related to their Institutional Responsibilities as follows:

Investigators shall log into MAESTRO and submit their FCOI information

Within 30 days of the Investigator’s initial employment date;
Annually not later than August 31st;
Within 30 days after acquiring a new significant financial interest (SFI) requiring disclosure; and
For those Investigators participating in PHS-funded research, not later than the application date for PHS-funded research, except that an Investigator who will be participating in an ongoing PHS-funded research project must submit a Financial Disclosure Statement within 30 days of the Investigator’s initial employment date.

Step 2. Review of Financial Disclosure Statements

The COI Official shall review the Financial Disclosure Statement(s) submitted by each Investigator and determine whether an SFI is related to research in which an Investigator is participating; and whether an FCOI exists.

An FCOI exists when the COI Official reasonably determines that an SFI held by an Investigator or a Covered Family Member could directly and significantly affect the design, conduct, or reporting of the Investigator’s research.

Step 3. Management of Financial Conflicts of Interest

If a COI Official determines that an FCOI exists, the COI Official, or designee, shall notify the Investigator in writing and work with the Investigator to develop a Management Plan specifying the steps to be taken to manage, reduce, or eliminate the FCOI.

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