To protect against the potential risks involved with financial conflicts of interest in research and to comply with federal regulations, Saint Louis University has developed a financial conflict of interest policy.
The University believes that establishing clear guidelines and principles for disclosing and managing potential, actual and apparent conflicts of interest will assist in ensuring that the highest level of integrity is maintained in SLU's research endeavors. The existence of a financial conflict of interest does not indicate wrong doing on the part of the investigator; however, if a conflict exists, it must be reduced, managed or eliminated.
Submitting a Financial Conflict of Interest Disclosure
The electronic Financial Conflict of Interest (eFCOI) forms are the sole source of submitting Financial Conflict of Interest in research disclosure forms for review and approval. The eFCOI disclosures are accessible through Electronic Research Services (eRS). Read and download a step-by-step guide on completing the eCOI disclosure.
If you have not previously completed the Collaborative Institutional Training Initiative (CITI) Conflict of Interest training course, you must complete it at citiprogram.org prior to the submission of your eCOI disclosure. Note that it may take up to 48 hours for eRS to retrieve your completed training. For instructions on setting up your account with CITI,
After completing the CITI Conflict of Interest course, you can login to eRS to complete your eCOI disclosure. Once logged in, click on "Submit My Current eCOI" to begin. You must answer all questions in order to submit your eCOI disclosure.
If you do not submit your eCOI disclosure within 30 days of your initialization, you will no longer have access to other eRS system areas until the disclosure has been submitted.
Any faculty, staff or graduate student engaged in externally-funded research who does not submit an eCOI disclosure or who does not comply with the Financial Conflict of Interest in Research Policy will be referred to the vice president of research for corrective action.
For any more information regarding the Financial Conflict of Interest in Research Policy, email COI@slu.edu or call 314-977-7047.
Frequently Asked Questions
A financial conflict of interest in research refers to situations in which significant financial interests or other personal considerations may compromise or could appear to compromise a researcher's professional judgment or integrity.
- SLU personnel: All SLU faculty, staff, students (except undergraduates) and other trainees (regardless of pay) listed on an application and/or award for external research funding.
- Non-SLU personnel paid by sub-award: All listed Non-SLU senior/key personnel (regardless of pay) listed on an application and/or award for external research funding.
- Non-SLU personnel not covered by subaward: All other non-SLU individuals responsible for the design, conduct or reporting of research (if a non-SLU individual is not identified as senior/key personnel, then the principal investigator must determine whether the Non-SLU individual is responsible for the design, conduct or reporting of research).
All faculty, staff and students (except undergraduates) involved in research at Saint Louis University must submit a yearly financial conflict of interest disclosure form, whether or not an actual conflict of interest exists. If the office of Responsible Conduct of Research finds that your disclosure results in a potential conflict that needs to be managed, you will be contacted for further information and instruction.
The electronic Financial Conflict of Interest (eFCOI) forms are the sole source of submitting financial conflict of interest in research disclosure forms for review and approval. Login to the eRS system at ers.slu.edu/ers to submit your financial conflict of interest.
If you are found to have a financial conflict of interest, your case will be reviewed by the Saint Louis University Conflict of Interest in Research Committee (COIRC). The COIRC meets monthly, and decides on appropriate management plans for individual cases. Appropriate management plans ensure the reduction, management or elimination of the conflict.
CITI Financial Conflict of Interest training is not CITI training for Human Subjects. You must take the CITI Conflict of Interest course if you are involved in research.
A lot of people think of CITI training as a course requirement for IRB. Saint Louis University uses CITI (Collaborative Institutional Training Initiative) for other courses as well, including training for animal subjects, responsible conduct of research (RCR), good clinical practice and the latest financial conflict of interest course. If you are involved in the design, conduct or reporting of research at SLU, you are required to first complete the Conflict of Interest course through CITI and then complete the eFCOI disclosure through eRS.
It may take up to 48 hours for eRS to recognize that you have completed the CITI Conflict of Interest course.
In order to comply with federal regulations for conflict of interest, Saint Louis University's Office of Research Integrity must be in receipt of all non-SLU disclosures prior to the submission of any external application for research funding and before award funds are disbursed.
If a non-SLU researcher will be part of a subaward agreement, then the subcontractor can provide written documentation indicating whether to use its own policy. Satisfactory documentation includes one of the following:
- Letter of Intent to Establish a Consortium Agreement (SLU as main)
- Letter of Intent to Establish a Consortium Agreement (SLU as sub-award)
- COI Certification Template Letter
If a non-SLU researcher is involved on the project without the issuance of a subaward or a subcontractor elects to comply with SLU's FCOI policies and procedures, then a non-SLU COI disclosure form is required prior to the submission of any external application for research funding and before award funds are disbursed. FCOI training will also be required at the time of award.
As documented FCOI disclosure is required prior to submission of an application, such disclosure should be initiated at least 10 working days in advance of the application deadline for non-SLU senior/key personnel and other non-SLU individuals involved in the design, conduct or reporting of research.