Financial Conflict of Interest (FCOI) Module Overview

The Financial Conflict of Interest (FCOI) reporting process allows institutions to report the existence of any identified financial conflicts of interest to the agency as required by the Federal regulation, specifically Title 42 Code of Federal Regulation Part 50 Subpart F for grants and cooperative agreements.

The FCOI module is an online interface within Commons that allows grantees and Federal staff to share information. The module is mandatory for all institutions. An institution's signing official completes this reporting process unless another Commons user is delegated with the proper authority to access the module.

The FCOI module in Commons allows institutional users to:

  • Initiate and prepare FCOI reports
  • Electronically submit reports and supporting documents as well as annual FCOI reports
  • Receive notification via email upon the submission and receipt of an FCOI
  • Search and view FCOI reports previously submitted through the Commons
  • Revise an Initial 2011 FCOI Report to update FCOI data following completion of the Retrospective Review or to submit a Mitigation Report when bias is found following the completion of a Retrospective Review.
  • Access history of actions
  • Assign FCOI access to other Commons users

Policy:  Additional information on the reporting requirements can be found within the Frequently Asked Questions on the Office of Extramural Research’s Financial Conflict of Interest website at