Financial Conflicts of Interest (FCOI)

Externally sponsored research and educational activities are a vital part of the Keene State College (KSC) mission. As these activities grow in sophistication and complexity they may intersect increasingly with industrial explorations and entrepreneurial ventures, creating for Investigators the potential for conflicting interests.

A financial conflict of interest (FCOI) exists when it can be reasonably determined that an Investigator's personal financial concerns could directly and significantly influence the design, conduct, or reporting of sponsored research or educational activities.

The purpose of the Keene State College FCOI  policy is to promote objectivity in research and educational activities by establishing standards and processes that provide a reasonable expectation that the design, conduct, and reporting of externally sponsored research and educational activities will be free from bias resulting from Investigator financial conflicts of interest.

Keene State College is compelled by both its mission and federal regulations to uphold these standards.

In brief, individuals responsible for the design, conduct, or reporting of any externally sponsored research or educational activity (or those seeking funding for such) must:

• Disclose significant financial interests (including those of your spouse/domestic partner, and dependent children) related to your institutional responsibilities by completing a Financial Conflict of Interest Screening and Disclosure form prior to submission of any grant application. Verification of disclosure will become part of the proposal routing/approval process utilized by OSPR.
• In the event of an award, update this disclosure at key points throughout the life of the award.
• Abide by the management plan instituted by the FCOI Review Officer in instances where a financial conflict of interest exists and must be managed throughout the life of an award.
• Complete training with regard to financial conflicts of interest prior to expenditure of funds and at least once every four years (in the event of an award).  Training will be online through CITI, our provider for other sponsored projects and research-related training.

Full FCOI Policy

Financial Conflict of Interest (FCOI) Screening/Disclosure Form

Keene State College FCOI Public Accessibility

Keene State College recognizes the importance of transparency, and that some sponsors require information about FCOIs to be made accessible to the public.

The College maintains this FCOI Public Accessibility webpage to fulfill this obligation. In instances where a financial conflict of interest of senior/key personnel has been managed (rather than eliminated) the following information will be made available to the public prior to expenditure of funds:

• Name of Investigator with the financial conflict of interest, title, role on the research project.
• Name of Entity with which the Investigator has a financial conflict of interest
• Nature of the financial interest (e.g., equity, consulting fee, travel reimbursement, honorarium)
• Approximate value of the financial interest

This information will be updated annually throughout the life of the funded project, and within 60 days of any new disclosure determined to be a financial conflict of interests. The information will remain available for 3 years from the date of the most recent update of the information.

Keene State College currently has no Financial Conflicts of Interest requiring management.