The Public Health Service (PHS)/ National Institutes of Health (NIH) published final rules regarding its Financial Conflicts of Interest regulations, effective August 24, 2012. An Institution applying for or receiving PHS funding from a grant, cooperative agreement, or contract that is covered by this rule must be in full compliance with all of the regulatory requirements and have a Financial Conflict of Interest (FCOI) policy publicly accessible.

NMSU will abide by the published final rules for PHS federal grants.  Submit the required federal forms for the PHS proposals (a) to the federal agency, (b) to all agencies that have adopted the federal regulations, and (c) to all flow-through PHS related subcontracts.

Principal investigators along with those who have financial or other interest(s) related to the proposed research project are required to undergo “Principal Investigator Training” (PI Certification) through the Office of Research Administration Services (RAS).  “Investigator” means anyone who has the responsibility for the design, conduct, or reporting of the research.  Each Investigator who has a positive disclosure must complete an original “Disclosure of Financial Interests” form. The federal disclosure form(s) are attached to the certification form, all of which are submitted at the time of proposal submission for a federal grant or contract or a subcontract where there are federal flow through funds. Those Investigators who do not have financial interests do not need to complete and submit the federal disclosure form.

The certification and individual disclosures are required for all new, renewal, revision, supplement, and continuation applications to any federal agencies and as new Significant Financial Interests are obtained.

Federal regulations require that NMSU do the following: (1) collect disclosures at the time of proposal submission; (2) review the disclosures and determine whether any of the reported financial interests could directly and significantly affect the design, conduct, or reporting of the research; and, if so (3) report to the PHS or NSF or awarding agency the existence of such conflicting interest(s) prior to the expenditure of awarded funds.