UGA Policy on Conflicts of Interest in Sponsored Programs complies with U.S. Department of Health and Human Services (DHHS) regulations for all Public Health Services (PHS) units, including the NIH, CDC, FDA, Indian Health Service (IHS), Health Resources and Services Administration (HRSA), and the Agency for Healthcare Research and Quality (AHRQ).
UGA applies the PHS requirements ONLY to those Investigators submitting to PHS units. However, all UGA investigators must use the DHHS/PHS Disclosure of Significant Financial Interests form when required to do so. As a reminder, all University employees must comply with UGA’s Policy on Conflicts of Interest in Sponsored Programs and must disclose any activity that might constitute a financial conflict of interest.
PHS Investigator Disclosures
- All PHS Investigators (defined as “the Project Director or Principal Investigator and any other person, regardless of title or position, who is responsible for the design, conduct, or reporting of PHS-funded projects, either funded or proposed”) are covered.
- Investigators must file an annual Disclosure of Significant Financial Interests (SFIs) that is retrospective rather than prospective, covering the 12-month period prior to a proposal’s submission. A disclosure update is required within 30 days of discovering the presence of an unreported SFI or acquiring a new SFI.
- The Disclosure must cover all financial interests that have an annual monetary value of $5,000 or more, whether or not the value is readily ascertainable.
- The Disclosure must have been filed by the time of proposal submission for any proposal submitted on or after August 25, 2012.
- PHS regulations apply to competing continuation awards. Your out year awards will be held up if you have not filed a disclosure in the previous 12 months or if you have not completed the FCOI training. Pending awards will be allowed to proceed for a subaward for any period prior to you having met the required disclosure and training requirements.
UGA employees disclose in the eResearch Portal.
Non-UGA employees must complete the Annual Disclosure of Financial Interests for Non-University of Georgia Investigators.
Conflict of Interest training/education is required for all Investigators on PHS grant and cooperative agreement proposals. Training for UGA Investigators will be provided via the Professional Education Portal that UGA uses for Responsible Conduct in Research and Human Subjects training.
Training must be completed prior to an expense being recorded in UGA’s official records (i.e., training is not required at proposal time but must have been completed by award time). Refresher courses are required every four (4) years.