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NIH Financial COI

Investigators who are part of a US National Institutes of Health (NIH) study have additional Financial COI (FCOI) disclosure and training requirements.

This requirement is mandated under the 2011 Public Health Service regulations and is in addition to the requirements for submitting an annual PHSA COI declaration form.

The information here applies to NIH investigators at BC Cancer. If you are an NIH Investigator elsewhere at PHSA, you will be covered by the NIH process at your affiliated university: UBC, SFU, or UVic

NIH investigators at BC Cancer

If you are an investigator on an NIH proposal or project at BC Cancer, you will need to make sure to:

The BC Cancer Office of Research Facilitation (ORF) will not sign off on any NIH proposal until all list investigators have completed the items above.


Two online training tutorials must be completed by each NIH Investigator before engaging in NIH-funded research:

Training certificates need to be uploaded into the PHSA COI Declaration form. Every four years, an automated email will be sent to you reminding you to renew your training.

Disclosure & Review

NIH regulations require the disclosure to PHSA of any significant financial interests held by an investigator. For your convenience, this disclosure is built into the PHSA COI Declaration website as an additional section. If you are a BC Cancer NIH investigator, simply complete that section and you will be in compliance with both the NIH regulations and PHSA Research COI Policy. Read PHSA's instructions for submitting FCOI disclosures.

As required by NIH regulations, the PHSA Institutional Official (IO) reviews all BC Cancer NIH Investigators' COI forms. If the IO finds that you have a conflict, you will need to develop a management plan to submit to the NIH.   
Management Plans

In order to ensure that the necessary information is sent to the NIH using the eRA Commons, you should use the BC Cancer/PHSA NIH FCOI Management Plan Template. Remember, all information given to the NIH is subject to freedom of information requests.

Per project, you need to include the following information:

  • Role and principal duties you have on research project,
  • Conditions of management plan (e.g., eliminate equity, inform colleagues, etc.)
  • How this manages the conflict,
  • How the plan will be monitored, and
  • Other relevant information.

View a sample NIH Management Plan.


PHSA must report to NIH any identified financial conflicts of interests (FCOIs). British Columbia's legislation, Freedom of Information and Protection of Privacy Act (FIPPA), requires that PHSA has the consent from the person with the FCOI (Investigator, spouse, and/or dependent child) to send this information outside of Canada to the NIH.   

If there is an FCOI:

  1. Sign the NIH FCOI Consent Form: Whomever has the FCOI must sign (you, your spouse, or dependent child). If you have used the management plan template and you have the FCOI, you only need to sign the included consent form to complete the process. Parent(s)/guardian(s)/substitute decision-makers (legally authorized representative) can sign on behalf of dependent child if the child is under the age of 19.
  2. Email signed form to
  3. Renew your consent if FCOI changes, or every three years if the FCOI is still in effect.

The consent covers:

  • BC Cancer/PHSA permission to report to NIH your FCOI and management plan
  • Allows BC Cancer/PHSA to disclose your FCOI if requested by a member of the public. Note: your spouse's and/or dependent child's name will not be included in the public disclosure. The FCOI will only be linked to your name.
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SOURCE: NIH Financial COI ( )
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