Other Organizations and Foundation that Follow PHS Requirements

In addition to PHS agencies, several organizations have adopted the PHS conflict of interest requirements, including:

• Alliance for Lupus Research (ALR)
• Alpha-1 Foundation
• American Asthma Foundation
• American Cancer Society (ACS)
• American Heart Association (AHA)
• American Lung Association (ALA)
• Arthritis Foundation (AF)
• ​CurePSP
• ​Juvenile Diabetes Research Foundation (JDRF)
• Lupus Foundation of America (LFA)
• Patient-Centered Outcomes Research Institute (PCORI)
• Susan G. Komen for the Cure

Check the terms and conditions of your award to determine whether the funder follows PHS conflict of interest requirements, or reach out to your post-award contact in Sponsored Projects for assistance. 

Financial Conflict of Interest Training 

Investigators must complete financial conflict of interest training prior to engaging in new or continuing awards funded by the PHS, the DOE and foundations that follow PHS conflict of interest regulations.

Investigators have to be re-trained every four years and whenever there is a change to the institution's conflict of interest policy that affects the investigators' obligations. The institution must also re-train any investigator who has been found to not be in compliance with the regulations and/or Brown's conflict of interest policy.

Financial conflict of interest training completed at another institution cannot be used as a substitute for Brown’s training. Training must incorporate institutional policies and procedures, and since those vary, training must be taken “locally” at your current institution, even if you took the required training less than four years ago at another institution.

However, Brown offers an abridged version of the financial conflict of interest training for anyone who has taken the required training within the last four years at another institution. Contact the conflict of interest administrator for more information.

Traincaster Online Training Module

Brown’s online financial conflict of interest training module is available through Traincaster. The module takes approximately 15 minutes to complete and includes a quiz.  

The training module should be assigned to you. If you do not have a Traincaster account, or if you cannot find the financial conflict of interest training module, please contact the conflict of interest administrator.

Investigators who have taken the financial conflict of interest training through Brown’s Traincaster system will receive automatic notifications and reminders when they are due for re-training.

• Traincaster Login with Brown Username
• Traincaster Login without Brown Username

Report New Significant Financial Interests

Investigators participating in PHS- or DOE-funded research are required to submit an updated disclosure of significant financial interests within 30 days of discovering or acquiring a new significant financial interest. This is a requirement under federal conflict of interest regulations. Updated COI form must be submitted via InfoEd.

A significant financial interest is considered “new” if:

• You have never previously reported it to the University
• It is a different type or nature of significant financial interest (e.g., royalty payment, consulting fees) than what had previously been disclosed from the same source or is the same type or nature but from a different source.
• You previously reported the financial interest but it did not meet the minimum threshold to be considered a significant financial interest (i.e., under $5,000).

Late Reporting of Significant Financial Interests

If you report a new significant financial interest late, after the 30 days have passed, per federal conflict of interest regulations, the institution may need to conduct a “retrospective review” if the significant financial interest is determined to create a financial conflict of interest with your PHS- or DOE-funded research. The purpose of the retrospective review is to determine whether any of your research, or portions thereof, conducted during the time period of the non-compliance, was biased in the design, conduct, or reporting of such research. 

Retrospective reviews are time-consuming and burdensome to the institution as well as the investigator. The results of the retrospective review may also need to be reported to the National Institutes of Health (NIH) or DOE.

Report Sponsored or Reimbursed Travel

Investigators who are participating in PHS- or DOE-funded research are required to report to the University the occurrence of any reimbursed or sponsored travel. 

Reimbursed travel is travel for which the investigator is directly reimbursed by the sponsoring entity. 

Sponsored travel is travel that is paid directly by the sponsoring entity and is not reimbursed to the investigator (e.g., a professional organization pays directly for your flight and hotel expenses when you attend the organization’s conference as an invited speaker).

Investigators on research projects funded by the PHS, the DOE and certain foundations are required under federal law to report reimbursed or sponsored travel that is related to the investigator’s institutional responsibilities or professional expertise. The institution can establish internal thresholds for reporting and reviewing travel. At Brown, the threshold has been set to $5,000 for any 12-month period.

The $5,000 threshold does not mean that an investigator cannot have sponsored or reimbursed travel of more than $5,000; it means that any travel that exceeds this threshold must be reported. Spousal or dependent children travel is also reportable if it is related to your University responsibilities and professional expertise and meets Brown’s threshold.

Information Required for Travel Reporting

When reporting reimbursed or sponsored travel, you will need to provide:

• the name of the company or organization that sponsored or reimbursed the travel
• the destination
• travel dates (departure and return dates)
• the approximate dollar value of the sponsored or reimbursed travel
• the purpose of the trip (business purpose)

Exceptions to Travel Reporting Requirement

Investigators do not have to report travel when it is reimbursed or sponsored by: 

• a federal, state or local government agency 
• an institution of higher education as defined by federal code (20 U.S.C. 1001 (a)) 
• an academic teaching hospital
• a medical center
• a research institution that is affiliated with an institution of higher education

Public Accessibility

The PHS and DoE require that Brown University provide public access to certain information regarding financial conflicts of interest held by senior/key personnel on Brown research projects funded by these federal agencies. 

Upon receiving a public access request, Brown will make available the following information regarding an investigator's financial conflict of interest:

• investigator's name
• investigator's title and role in the research project
• name of the entity/entities in which the investigator holds the financial interest(s)
• nature of the financial interest(s)
• approximate value of the financial interest(s) (by ranges)

Research Integrity team members will notify any investigator about whom a public access request has been made. To make a public access request, email coi@brown.edu.

NASA released a new conflict of interest policy that became effective on December 1, 2023. Brown’s Research Integrity team has incorporated the new regulations into existing policies and processes.

Both NASA and the NSF require that investigators on research funded by these agencies report “venture and other capital financing” when reporting significant financial interests. Venture capital is a form of private equity and a type of financing that investors provide to startup companies and small businesses.

Brown researchers funded by either the NSF or NASA are required to disclose any venture or other capital financing on their Conflict of Interest Reporting Forms (effective January 24, 2023 for NSF-funded researchers). To report such funding or financing, please submit a new form in InfoEd and add the venture funding as a comment for the relevant startup or other entity.

• NASA Conflict of Interest Policy
• NSF PAPPG