Reminder of Financial Conflict of Interest Requirements for All NIH-Supported Institutions

Notice Number: NOT-OD-05-013

Key Dates
Release Date: December 6, 2004

Issued by
National Institutes of Health (NIH), (

This Notice is intended as a reminder of the financial conflict of interest (FCOI) requirements for all institutions and contractors that receive from the National Institutes of Health (NIH) grants or contract support to conduct research. Although the FCOI requirements summarized here are longstanding, the world of scientific collaboration has changed and is continuing to change very quickly. New and more complex types of relationships are emerging and with them potential FCOIs. In light of these evolving financial relationships, institutions and contracting organizations that receive NIH support to conduct research are hereby reminded of the requirement to identify and manage the FCOIs of all NIH-supported investigators and to comply with the associated reporting requirements.

As you know, the Code of Federal Regulations (CFR) 42, Part 50, Subpart F, Responsibility of Applicants for Promoting Objectivity in Research for which PHS Funding Is Sought and 45 CFR Part 94.1, Responsible Prospective Contractors, promote objectivity in research by establishing standards to ensure that the design, conduct, and reporting of research funded under PHS grants, cooperative agreements, or contracts will not be biased by a conflicting financial interest of an investigator. It therefore requires that institutions seeking NIH support for research have a written administrative process to identify and manage FCOI. Institutions must inform investigators of the conflict of interest policy and of their individual responsibilities.

Further, the grantee or contractor must:

  1. Inform the relevant Institute or Center Chief Grants Management Officer* or Chief Contracting Officer**, as appropriate, of the existence of any FCOI before spending any NIH funds awarded under a new award. Conflicts identified during the award period must be reported within 60 days of identifying them. These reports must indicate whether the FCOI has been managed, reduced, or eliminated.
  2. Make additional information available to NIH upon request.

Please review the information provided at this website: It contains an NIH assessment of how FCOI procedures are being implemented across 300 of NIH's top funded grantee institutions and provides helpful suggestions for resolving and managing these conflicts.

If you have any questions related to FCOI regulations involving NIH funded grants, cooperative agreements, or contracts, please send your question to Please do not send any FCOI notifications to this mailbox.

Thank you for your attention to these important issues.

* Chief Grants Management Officer list:

** Chief Contracting Officer list:

Weekly TOC for this Announcement
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