Legacy Research Institute

Transforming medical care through science, technology, and innovation.

GRANTS MANAGEMENT - Financial Conflict of Interest

Supporting our researchers' projects from concept to close-out.

Maintaining the objectivity of research is crucial for earning and preserving public confidence. As you are involved in the design, execution, or reporting of research funded by the Public Health Service (PHS), compliance with federal regulations is mandatory. As part of this compliance, you are obliged to undertake the CITI Financial Conflict of Interest (FCOI or COI) training and complete and submit the associated disclosure form. This process is essential to uphold the integrity of our research.

Part 1: Training

To fulfill the CITI Training requirements:

  1. Complete the following two modules:
    • Financial Conflict of Interest: Overview, Investigator Responsibilities, and COI Rules (COI-Basic) (ID:15070)
    • Institutional Responsibilities as They Affect Investigators (COI-Basic) (ID:15072)

    If you've already finished these modules, please email your completion record to research-grants@lhs.org.

  2. Creating or Accessing Your CITI Training Account:
    • If you don't have an account, go to the CITI Training website, click on ‘register’, and follow the instructions to create one.
    • If you already have an account, simply log in as you normally would.

  3. Selecting the Course:
    • Once logged in, find and select the ‘Conflict of Interest mini-course’ from the list of courses. This action will add both required modules to your course list.
    • Then, open the ‘Legacy Health courses’ dropdown menu and choose the course to begin.

After Completing the Training:

Note: Although the CITI website indicates that the training expires in 2 years, you are only required to retake it every 4 years.

Part 2: Disclosure

Below is the LRI FCOI Disclosure form which should be filled out after your training is complete. You'll also find the FAQ with an overview of the disclosure process and the Legacy COI policy. This is usually done via an online form that will be sent to you, but if you need to make an interim disclosure there's a stand-alone form below that can be used.

The disclosure is valid for a calendar year (Jan-Dec) and we will ask you to update it every January while you are funded. You are also required to submit an updated disclosure form within thirty (30) days of acquiring or discovering any new Significant Financial Interest(s). 

To learn more about Conflict-of-Interest regulations in relation to NIH grants, visit: https://grants.nih.gov/grants/policy/coi/coi_faqs.htm

Forms and Policies

LRI FCOI Disclosure Form


Legacy Policy 100.88: Conflict of Interest in Public Health Service Funded Research

Legacy Policy 100.67: Standards of Conduct