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Financial Conflict of Interest Requirements

In compliance with federal regulations San Jose State University and the San Jose State University Research Foundation require Principal Investigators and other key personnel on a sponsored project to disclose a list of Significant Financial Interests (and those of his/her spouse and dependent children) that could be reasonably expected to bias the design, conduct, or reporting of the project. PIs, Co-PIs, and in some instances, key personnel listed on a proposal for external funding must complete a Financial Conflict of Interest disclosure form (by completing the California Form 700U or SJSURF Financial Conflict of Interest forms as applicable) before submitting a proposal to and expending on a sponsored project funded by NSF-, PHS-, other agencies adopting federal requirements, or non-governmental sponsors.

As SJSURF reported in the August 2011 and October 2011 issues of the monthly OSP Bulletin, NEW federal regulations regarding financial conflict of interest (FCOI) have been issued by the Department of Health and Human Services and went into effect August 24, 2012.

The new regulations can be found here:

The revised SJSURF Financial Conflict of Interest Policy can be found here:

Mandatory Financial Conflict of Interest Tutorial

Investigators are required to complete mandatory training before engaging in research funding by PHS. SJSU has engaged CITI for training delivery. The tutorial highlights the key Federal requirements for which the Investigator, SJSU, and NIH or other PHS-Funded agencies are accountable under the new regulation.

For More Policy and Training Information, Visit the Following Links:

Academic Senate Policy S99-11

42 CFR Part 50, 45 CFR Part 94

CSU HR 2005-38



NIH FCOI Tutorial


Understanding FCOI: Ten Things You Should Know or Do

If you have any remaining questions about the Financial Conflict of Interest Policy or regarding completing the FCOI forms, please contact your designated Sponsored Programs Manager.

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