Financial Conflict of Interest (fCOI) in Research

Ascension Wisconsin is committed to ensuring the objectivity of human subject research, and to avoid actual or perceived conflicts of interest in such research by identifying, reporting, evaluating and managing conflicts. 

Ascension Wisconsin associates, staff and affiliates are responsible for disclosing financial relationships that might result in or have the appearance of a conflict, per institutional policy. In general, this includes anyone who has the authority to make independent decisions related to the design, conduct, or reporting of an Ascension Wisconsin research project, but not including individuals who perform only incidental or isolated tasks related to the project. The term “conflict of interest in research” refers to situations in which financial or other personal considerations may compromise, or have the appearance of compromising, an investigator’s professional judgment in conducting or reporting research. 

All significant financial interests are reviewed to determine whether a financial conflict of interest exists, and, if so, what actions should be taken by the Institution to manage, reduce, or eliminate the conflict of interest. Review the Policy, Guidance document and other resources for details about the reporting process, who it applies to, and how and when to submit a disclosure.


All research staff who are working on projects with external funding, or have a fCOI must submit a fCOI disclosure at least annually.


Policy: fCOI in Research
(requires PolicyStat login)
RI&P Guidance of fCOI

Public Health Service (PHS) Regulation 

Frequently Asked Questions (FAQs)

  •  Who needs to complete a disclosure?
    • All study personnel listed on a funded research project
    • All study personnel listed on a project where they have a financial interest, regardless of funding
  •  When does a disclosure need to be completed?
    • Before being involved in any funded research;
    • Annually not later than July 1;
    • Before applying for PHS research funding; and
    • Within 30 days of a new or updated Significant Financial Interest, when listed on PHS funded research.
    • If there is a management plan in place for a previously reported fCOI, researchers may be asked to complete a disclosure more frequently, for example every 6 months.
  •  How do you complete a fCOI disclosure?
    The fCOI disclosures are completed online and should take most users only a few minutes to complete.  An SFI Disclosure Form must be submitted by each Covered Individual.
  •  Who needs to complete COI training?
    • All study personnel listed on a project, regardless of funding, complete a COI course as part of the basic CITI Program training module
    • All study personnel listed on a PHS funded project, must take the additional complete Conflicts of Interest Module in CITI
  •  How do you compete COI training?

    All Conflict of Interest training is complete through the online CITI Program. Training needs to be completed at least every 3 years.

  •  Who reviews fCOI and management plans?

    The Ascension Wisconsin IRB serves as the review committee for research related fCOI. The IRB, in conjunction with the Institution’s Conflict of Interest Official (in Corporate Responsibility), review and approve disclosures and management plans. Research Integrity and Protection staff oversee the process and facilitate the reviews.