This Is Auburn Senior Vice President for Research & Economic Development Research Integrity - Financial Conflict of Interest (FCOI)
 

Department of Energy (DOE) FCOI Regulations 

 

PI's Role Timing Training Questionnaire

 

►Regulatory Requirements.  "This DOE Interim Conflict of Interest Policy for Financial Assistance (“DOE Interim COI Policy” or “Policy”) establishes standards that provide a reasonable expectation that the design, conduct, and reporting of projects wholly or in part funded under Department of Energy (DOE) financial assistance awards (e.g., a grant, cooperative agreement, or technology investment agreement) will be free from bias resulting from financial conflicts of interest or organizational conflicts of interest." Effective June 18, 2022, DOE Interim Conflict of Interest Policy.

  • Mandate. The FCOI Regulations require that AU "have an up-to-date, written, and enforced administrative process to identify and manage conflicts of interest with respect to all projects for which financial assistance funding is sought or received from DOE." (DOE Interim Conflict of Interest Policy, Subpart A).
  • Applicability.
    • This DOE Interim COI Policy is applicable to each non-Federal entity that is applying for or that receives a DOE financial assistance award and, through the implementation of this policy by the non-Federal entity, to each Investigator who is planning to participate in or is participating in the project funded wholly or in part under the DOE financial assistance award, and to each non-federal entity sub-recipient under the award." (DOE Interim Conflict of Interest Policy, Appendix I, Section II).
  • Frequently Asked Questions. DOE has issued FAQs for the FCOI regulations.  

►PI Training and Disclosure Oversight Responsibilities.

  • Continuing Responsibilities. On a timely basis, from the proposal stage throughout the duration of a project subject to the FCOI regulations, Principal Investigators are responsible for:
    • 1. Identifying Investigators on a proposal, award, and modification to the scope of work, and
    • 2. Ensuring Investigators take FCOI Training and submit FCOI Disclosure Questionnaires. 
  • Who is an Investigator? "Investigator means the Principal Investigator (PI) and any other person, regardless of title or position, who is responsible for the purpose, design, conduct, or reporting of a project funded by DOE or proposed for funding by DOE. DOE program offices have the discretion to expand the definition to include also any person who participates in the purpose, design, conduct, or reporting of a project funded by DOE or proposed for funding by DOE. Such expansion will be specified in the applicable funding opportunity announcement and/or terms and conditions of the financial assistance award." (DOE Interim Conflict of Interest Policy, Appendix I, Section III).
    • The term “investigator” may include collaborators, consultants, or graduate (Master’s or PhD) students where individuals holding those positions otherwise meet the definition of investigator.
    • A project’s “purpose” has its common meaning -- the reason for which a project is proposed or carried out. That reason may include, for example, the desire to improve a technology or solve a specific energy-related problem. Individuals responsible for the “purpose” of a project may not be the same individuals responsible for the “design, conduct and reporting”, but their financial interests could still bias the project because the purpose can underpin the whole reason for proposing the project. (U.S. Department of Energy, FAQ Interim COI Policy, No. 8).

►When to Train and Disclose.

  • Before Proposal Submission. Each Investigator planning to participate in research subject to the FCOI regulations and each Investigator identified by the PI on a particular proposal submission subject to the FCOI regulations is required to:
    • 1. Complete FCOI Training, and
    • 2. Submit a FCOI Disclosure Questionnaire including the Investigator's Significant Financial Interests and those of their Immediate Family. 
  • Disclosure after Proposal Submission. 
    • 1. Newly Added Investigator. If the PI identifies any Investigators who did not submit a Disclosure Questionnaire prior to proposal submission, they must submit a Disclosure Questionnaire before engaging in research. 
    • 2. Recertification/Revision of Prior Disclosure. Each Investigator is required to recertify/revise their Disclosure Questionnaire at certain points during the reporting year:
      • Within thirty (30) days of discovering or acquiring a new Significant Financial Interest for themselves or their Immediate Family.
    • 3. Annual Disclosure. Investigators are required to submit a Disclosure Questionnaire annually.
  • Training after Proposal Submission. 
    • 1. Newly Added Investigator. If the PI identifies any Investigators who did not complete FCOI Training prior to proposal submission, they must complete the FCOI Training before engaging in research. 
    • 2. Expiration of Training. Each Investigator is required to complete FCOI Training at least every four (4) years.
    • 3. In Other Circumstances. An Investigator must complete FCOI Training immediately when any of the following apply:
      • The University revises its Financial Conflict of Interest Policy or Procedures in any manner that affects the requirements of Investigators, or
      • An Investigator is newly appointed at the University; or
      • The University finds that an Investigator is not in compliance with the University’s FCOI Policy, Procedures, or Management Plan. ​​

►How to Train: Online via CITI.

  • New CITI Users. Use this Guide to help you register, enroll in the Conflict of Interest course and complete your DOE COI Training.  
  • Previously Registered CITI Users. If you need to complete FCOI training, login to CITI, click "Add a Course or Update Learner Group" and add the DOE Conflict of Interest course.
  • Training Expiration and Extension. The FCOI Training Certificate earned after completing the Conflict of Interest course expires after four (4) years. Completing the FCOI Refresher course extends your Training Certificate for another four (4) years.
    • ​Automatic Refresher Enrollment. You should receive an email from CITI informing you that your FCOI training is expiring and enrolling you in the FCOI Refresher course necessary to maintain your FCOI Training Certificate. Use the login in the email to access CITI and extend your Training Certificate.
  • Transferring Training Credits to Auburn University. If you would like to receive credit at Auburn University for CITI Conflict of Interest modules previously taken at another institution, follow these CITI requirements to affiliate with AU and transfer credit. Modules transferred may or may not match the required modules in the AU Conflict of Interest course. You may need to complete additional modules to get full credit for the AU course.

►How to Disclose: Starting January 2024, Auburn University introduced a new electronic research administration and compliance system. All annual disclosures must now be submitted online through the Endeavor platform.​

  • New Endeavor Users
    • Accessing Endeavor: Using Auburn credentials, log in to Endeavor, and navigate to the COI tab.
    • Helpful Guide:  Resources, Videos, and FAQs are available to help you access your Endeavor account, log in, and complete your Disclosure Profile. 
    • Even if you have no revisions, you must re-certify your Disclosure Profile.
    • Auburn Students:  Please contact coiadmin@auburn.edu if you need to submit a disclosure.
    • External individuals:  Please contact coiadmin@auburn.edu if you need to submit a disclosure.