PHS Investigators: Financial Disclosure and Training Requirements
Required Training for PHS Investigators
A Health and Human Services regulation, 42 CFR Part 50 Subpart F, on financial disclosure for Public Health Service (PHS)-funded investigators requires training for anyone involved in the design, conduct, and analysis of PHS-funded research, including PIs, co-PIs, academic professional research staff, postdoctoral research associates, and graduate research assistants.
- Training must be completed by all new investigators before engaging in PHS-funded research.
- Training must be completed by all investigators currently involved in PHS projects prior to renewal or continuation.
If your research or employment is funded by the PHS (list of agencies), this regulation will affect you. Training and disclosure are required.
Pre-Award Financial Disclosure
At the time of PHS proposal submission, renewal, or continuation principal investigators and co-investigators will be asked to certify that financial disclosures and travel disclosures are up to date for all investigators expected to participate in the project.
Use the Sponsor Specific Disclosure within the START myDisclosures system to disclose significant financial interests and reportable sponsored travel.
If activities are disclosed that require review, the investigator and the unit head will be consulted. Investigators must submit this form even if no significant financial interest is disclosed. Disclosures will be reviewed in the Office of the Vice Chancellor for Research & Innovation (OVCRI), to determine if there are potential financial conflicts of interest (FCOI) relating to the individual's institutional responsibilities. The OVCRI will consult with the unit head(s) on the identification of FCOI as needed and will work with the unit head(s) to manage any FCOI that are identified.
"Just in Time" Disclosure, FCOI Management and Training for Awards and Renewals
Prior to initial award, renewal, or continuation, principal investigators will be asked to certify that financial disclosures, travel disclosures, and training are up to date for all investigators participating in the project using the myFCOI Checklist.
If between the time of proposal and the time of award an investigator has acquired a significant financial interest, he or she should use the Sponsor Specific Disclosure within the START myDisclosures system to disclose the unreported interests.
Information regarding subawards is available here.
- Subrecipient PHS Investigator Financial Interest Disclosure Form
- Subrecipient Certification of Financial Disclosure and Training for PHS Investigators
Ongoing Disclosures and Training
- All PHS investigators must be trained concerning the HHS requirements and the University of Illinois Policy on Conflicts of Commitment and Interest prior to initiating work on a PHS-funded project.
- PHS investigators must continue to disclose significant financial interests on an ongoing basis, within 30 days of acquiring a new interest.
- New PHS investigators who join a project must disclose significant financial interests upon joining the project and then continue to disclose significant financial interests on an ongoing basis.
- Any financial conflicts of interest that are identified must be managed or eliminated within 60 days.
- Externally sponsored or reimbursed travel must be disclosed by PHS investigators within 30 days.
Travel Disclosure for PHS Investigators
PHS investigators are required to disclose the occurrence of any reimbursed or sponsored travel (i.e., that which is paid on behalf of the investigator and not reimbursed to the investigator so that the exact monetary value may not be readily available), related to their institutional responsibilities. This disclosure requirement does not apply to travel that is reimbursed or sponsored by excluded sources as provided in the HHS regulation.
The travel disclosure requirement does not apply to travel that is reimbursed or sponsored by the following:
- Federal, state, or local government agency
- U.S. institution of higher education as defined at 20 U.S.C. 1001(a)
- Academic teaching hospital
- Medical center
- Research institute that is affiliated with a U.S. institution of higher education
Please note that reimbursement of travel by other non-profit agencies must be disclosed (e.g., American Heart Association, American Cancer Society, Nature Conservancy, etc.).
The Sponsor Specific Disclosure within the START myDisclosures system should be used to disclose reimbursed travel, in cases where no payment for services is also being made to the individual (e.g., travel to give presentations, travel associated with job interviews, travel to review proposals for non-profit agencies).
Travel disclosures entered on this web page will be reviewed in the Office of the Vice Chancellor for Research and Innovation. PHS investigators and their unit heads will be contacted if questions arise.
Travel associated with significant financial interests such as consulting, paid service on a Board of Directors or Advisory Committee, or other paid outside activities should generally be reported in conjunction with disclosure of the financial interest or paid outside activity. Please use the Sponsor Specific Disclosure within the START myDisclosures system for this purpose.
Watch the brief video below to determine whether disclosure of travel is required. If activities are disclosed that require review, the form will be routed to your unit head for signature.
SPA Processes for PHS-Funded Investigators
At the time of proposal submission, the principal investigator and co-principal investigators will be asked to sign a Proposal Intake Form confirming that all disclosures are up to date for researchers named in the PHS-funded proposal.
To avoid delays, it is recommended that all individuals who are expected to be involved in the design, conduct and reporting of PHS-funded research complete training and assure they are up to date on disclosures of significant financial interests.
“Just in Time” Stage
OSPRA will provide notification of the JIT request and a reminder to complete the disclosure form, required trainings, and the Certification Form.
- Please list the names of anyone who will be involved in the design, conduct or analysis of research on the funded project. Make sure that each person has completed (1) PHS Investigator Training and is up to date with (2a) PHS Investigator Financial Disclosure and (2b) Travel Disclosure. Note this for each investigator in columns 1 and 2 of the form.
- Ensure the Principal Investigator signs the certification form.
- Submit the form electronically to email@example.com. Staff in the Office of the Vice Chancellor for Research and Innovation will check the status of any conflicts of interest and return the form to OSPRA or contact the principal investigator for more information.
OSPRA will confirm with OVCRI that a signed certification form is on file prior to forwarding the award to SPA. Funds cannot be expended until all PHS investigators on the project are trained and up to date with their disclosures. Therefore, no anticipation accounts will be granted, or award funds created until OSPRA has received an approved certification form from the OVCRI.
Information regarding subawards is available here.
Forms for PHS-Funded Investigators
- PHS Investigator Financial Interest Disclosure Form
- Training Documentation Form
- PI Certification Form
- Subaward Forms:
- HHS Regulation Requirements Information: Please familiarize yourself with the requirements of the new HHS regulation by reviewing the information below.
- NIH Financial Conflict of Interest
- Federal Register
- List of PHS Agencies
- List of Non-PHS Agencies
- University of Illinois Policy on Conflicts of Commitment and Interest
- PHS FCOI Compliance Instructions (PDF)
If you have questions about the regulation or the university's Policy on Conflicts of Commitment and Interest or suggestions regarding the implementation of the HHS regulation, please contact Linda Lee Drozt (firstname.lastname@example.org, 217-333-0034).