Institutional Financial Conflict of Interest Policy

The Policy Documents tab of the Institutional Profile module lets you upload your institution‚Äôs Financial Conflict of Interest (FCOI) policy. Effective November 12, 2020, each institution must upload its FCOI policy to eRA Commons for review. The institutional FCOI is required and defined by regulations, which are linked on the Policy Documents tab in the Institution Profile module. The policy must be in PDF format under 6 MB in size. After uploading, NIH staff will review the policy and reject or accept it, and will notify you via one of your listed contact methods. For more information, refer to the Guide Notice NOT-OD-21-002 as well as the table of regulatory requirements on the new Policy Documents tab.

To access Closed toggler arrowthe Financial Conflict of Interest Policy screen:

Log into eRA Commons with a signing official (SO) role, go to the Institution Profile, and then click the Policy Documents tab.

To upload your FCOI policy to eRA Commons for Agency approval:

  1. On the Policy Documents tab of the Institution Profile module, click the green Upload button in the FCOI Policy Submission area.
  2. Locate the FCOI PDF and click Open.
  3. Optionally, before submitting, you can either view or delete the file you uploaded by clicking the View or Delete button in the FCOI Policy Submission area.
  4. Click the Submit button and the file will be routed to Agency officials for review.
  5. If you make a mistake, you can simply upload another PDF file and it replaces the first.

TIP: If nothing appears to happen when you upload, scroll to the top of the screen and check for error messages that may have appeared in a red bar. You can upload only a single file.

To view the FCOI policy that was previously submitted:

On the Policy Documents tab of the Institution Profile module, click the Policy ID number in the Prior FCOI Policy Submissions area.

Click the policy ID in the Prior FCOI Policy Submissions area

The PDF opens in your system PDF viewer.

To resubmit an FCOI policy that has been updated:

On the Policy Documents tab of the Institution Profile module, click the green Upload button in the FCOI Policy Submission area, upload a new file, then click Submit. If someone from NIH had contacted you about the policy, notify them of the re-submission.

See:

Institution Basic Information