Consistent with the requirements of the 2011 U.S. Public Health Service (PHS) regulations on Promoting Objectivity in Research (42 CFR Part 50 Subpart F and 45 CFR Part 94), the University of Padua has formulated the Policy on Financial Conflict of Interest (FCOI Policy) to identify and address potential, actual and apparent financial conflicts of interest. This policy is intended to increase the awareness of faculty and staff to the potential for financial conflicts of interest and to establish procedures whereby such conflicts may be avoided or properly managed. It applies to all applications as prime awardee or subawardee for PHS funding and to all PHS funded grants, cooperative agreements, research contracts, and subawards where the originating sponsor is PHS. PHS means also any of its operating agencies, i.e. the National Institutes of Health (NIH).

All investigators responsible for the design, conduct, or reporting of research funded directly or indirectly by the PHS must disclose any Significant Financial Interest (SFI) with respect to their institutional responsibilities through the Investigator Financial Interests Disclosure Form  prior to applying for PHS funded research, within 30 days of discovering or acquiring a new SFI and at least annually during the period of the award. Before any expenditure of any funds under a PHS-funded research project the University of Padua shall ensure public accessibility, via written response within 5 business days of a request of information concerning any SFI disclosed that meets the criteria described in the Policy, title X. Requirements for making information on FCOI policy and FCOI publicly accessible.

Prior to applying for any PHS funding or engaging in research related to any PHS-funded award or subaward  and at least every four years, all investigators must complete FCOI training at this link.

The complete PHS FCOI Policy implemented at the University of Padua is available for download (Italian version - English version).

External links:

• 42 CFR 50, Subpart F, Promoting Objectivity in Research (FCOI Regulation), as implemented in the 2011 Final Rule
• National Institutes of Health (NIH) FCOI page
• National Institutes of Health (NIH) FCOI FAQs