PHS-Funded Investigators & their Supervisors
The information on this page is to assist Investigators engaged in research funded by an agency of the Public Health Service (PHS) and their supervisors to comply with the University of Pittsburgh's revised 11-01-03 Conflict of Interest Policy for Faculty, Scholars, Researchers, Research Staff/Coordinators that reflects the revised Public Health Service regulations. The revised policy went into effect August 24, 2012.
Public Health Service (PHS) Agencies are:
- Agency for Healthcare Research and Quality (AHRQ)
- Agency for Toxic Substances and Disease Registry (ATSDR)
- Centers for Disease Control and Prevention (CDC)
- Food and Drug Administration (FDA)
- Health Resources and Services Administration (HRSA)
- Indian Health Service (IHS)
- National Institutes of Health (NIH)
- Substance Abuse and Mental Health Services Administration (SAMHSA)
Disclosing financial relationships on the PHS Faculty/Researcher form
ALL PHS-funded Investigators must complete the PHS Faculty/Researcher COI disclosure form, available in the University’s Superform system.
Please note: Those with dual appointments at the Univeristy and UPMC/UPP should complete the joint PHS Faculty/Researcher COI disclosure form available in My HUB to fulfill their University and UPMC COI reporting requirements at the same time.
Please visit the COI Filing Process web page for instructions for completing the PHS Faculty/Researcher form.
Department-level PHS COI Review of Consulting Contracts ($5,001-$10,000)
All University personnel who wish to engage in outside professional activities must seek the prospective approval of their department chair before entering into any agreements. Many faculty cap the total amount of consulting income in any 12 month period at $10,000 to avoid additional review and approval required by their School or the Industry Relationship Policy, and/or to allow them to remain as the PI of University research sponsored by or of commercial interest to the company with which they are consulting.
The PHS COI regulations, however, have a $5,000 reporting threshold and require that the University consider whether disclosed Significant Financial Interests (SFIs)* valued above this amount are related to, and give rise to a Financial Conflict of Interest (FCOI)** with, any PHS-funded research in which the individual is engaged. If the consulting contract/activity will provide more than $5,000, but not more than $10,000, in a 12 month period, this responsibility lies at the department level.
Please use the document below to assist you in making this determination. Any FCOIs identified and managed by the department must be reported to the COI Office so that the University can make the required institutional disclosure to the PHS funding agency.
All externally-funded Investigators (including those funded by the PHS) are required to complete the CITI COI course with re-certification required every four years. Please visit the COI Training Requirements webpage for additional information.
As required by the revised Public Health Service (PHS) regulations and in keeping with an emphasis on increasing transparency, institutions that receive PHS funding must provide information on a publicly accessible website about the Financial Conflicts of Interest (FCOI) disclosed by their Investigators and being managed by the University. In order to be considered an FCOI, the University has first determined that the financial interests are above a certain threshold related to a PHS-funded project, and that they could directly and significantly affect the design, conduct, or reporting of PHS-funded research. Managed FCOIs will be reported on the COI web site.
Please note that this posted information includes only interests of individual investigators, and does not reflect research grants or gifts to the University of Pittsburgh and reflects only those interests that meet the definition of an FCOI under the PHS regulations. Other public disclosures of outside interests, including disclosures by pharmaceutical or device companies, may have different information, as a result of different reporting obligations and regulations that govern those disclosures.
NIH FAQs on Revised COI Regulations
The NIH’s website has a wealth of useful information for Investigators; we especially encourage Investigators to review the Frequently Asked Questions.
*Significant Financial Interest: an external financial interest that would reasonably appear to be related to an individual’s institutional responsibilities (which include activities such as research, teaching, professional practice, institutional committee memberships, service on panels such as Institutional Review Boards or Data Safety and Monitoring Boards, and other administrative activities).** Financial Conflict of Interest (FCOI): a Significant Financial Interest (SFI)* that could directly and significantly affect the design, conduct, or reporting of PHS-funded research.