Sponsor-Specific Conflict of Interest Guidelines

Prior to expending funds under any grant, GW must review all investigator disclosures of financial interests and determine whether an FCOI exists.

Beyond the Public Health Service (PHS) FCOI rule, other federal rules exist, as well. For example, the HHS Common Rule may be applicable and the Institutional Review Board (IRB) may need to review COI issues.

The National Science Foundation (NSF) has similar COI requirements to PHS. NSF requires that all investigators must disclose (1) any "significant financial interest" to the responsible party with the institution if the significant interest "reasonably appear[s] to be affected by" the research, or (2) if the research could reasonably appear to affect the financial interests of the entity in which the Investigator holds a significant interest.

We maintain links to certain Conflict of Interest policies from across the government.  If your work is at all funded by Federal grants, check for Conflict of Interest reporting requirements. The GW COI policy also applies to non-federal sponsors with FCOI requirements (e.g., Alliance for Lupus Research, American Cancer Society, American Heart Association, Arthritis Foundation, Juvenile Diabetes Research Foundation, Lupus Foundation of America, Knight Foundation, Simon Foundation, Susan G. Komen for the Cure) and research contracts with non-federal entities.

  1. Public Health Service Regulations (Code of Federal Regulations)
  2. National Institutes of Health (NIH)
  3. National Science Foundation (NSF)
  4. Food and Drug Administration (FDA)
  5. Department of Energy
  6. Environmental Protection Agency (EPA)
  7. Department of Defense (DOD)
  8. Department of State
  9. U.S. Department of Agriculture (USDA)
  10. Department of Justice (DOJ)
  11. Department of Education (DoE)
  12. National Aeronautics and Space Administration (NASA)

Nonexclusive List of Sponsors that Follow Public Health Services (PHS) Conflict of Interest Disclosure Requirements

Alliance for Lupus Research

American Asthma Foundation

American Cancer Society

American Foundation for Suicide Prevention

American Heart Association

American Lung Association

Arthritis Foundation

Harrington Discovery Institute

Juvenile Diabetes Research Foundation

Lupus Foundation of America

Patient-Centered Outcomes Research Institute

Susan G. Komen for the Cure