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Financial Conflicts of Interest (COI)

in Sponsored Projects

U.S. Federal regulations require that institutions have policies and procedures in place to ensure that employees disclose any Significant Financial Interests (SFI) that may represent an actual or potential conflict of interest in Sponsored Projects. Idaho State University (ISU) recognizes its responsibilities as a public institution to encourage synergistic relationships between its employees and the public and private sectors as an important component of its Research, instructional, and service activities.

COI Process

Meeting Financial Conflict of Interest requirements at ISU requires the following steps:

The University’s Conflict of Interest in Sponsored Projects (COISP) policy requires faculty members, students, and all who are acting, or planning to act, as Key Personnel on Sponsored Projects to annually disclose whether or not they have a Significant Financial Conflicts of Interest (FCOI) in Sponsored Projects.

After Disclosure, the University can make an informed judgment about each case and require appropriate oversight, limitations, or prohibitions on the activity.

Definition of Key Personnel/Investigators:

ISU defines “key personnel” as those listed on a Cayuse proposal as the Lead Investigator (LI), Principal Investigator (PI) and Co-Principal Investigator (co-PI).  The LI and PI certify conflicts of interest when they submit a proposal through Cayuse. Co-PIs will receive an email asking them to certify conflicts of interest.

COI Training in CITI:

When an award is made by any external funder, all personnel listed in Cayuse as LI, PI or Co-PI must take the Conflict of Interest Training on CITI. An index WILL NOT be created and you will not be allowed to spend funds until this training is complete for all key personnel. When you complete the training a notice is sent to the Research Outreach and Compliance office, which then notifies Grants and Contracts accounting that you are ready to spend.

If you have a declared conflict of interest you will be contacted to develop a conflict management plan.

CITI on-line COI Modules

The COI modules can be reached using your ISU email account on the CITI website. 

Follow these steps:
1. Register for CITI online training. (
2. In the “Select Your Institution or Organization” drop-down box type "Idaho State University".
3. Create your own Username and password; then select the COI Learner Group
4. Then you will select Question 5 for the COI Curriculum.  ALSO GO TO QUESTION 8 AND SELECT “NOT AT THIS TIME.”
5. Research Outreach & Compliance is automatically notified when you successfully complete a course.

Do you have Questions about the COI training requirement?

Contact Tom Bailey, Research Compliance Coordinator at or (208) 282-2179.

CITI automatically contacts you by e-mail 90 days prior to the expiration date of your course certification.
Questions about the CITI online system? Contact Tom Bailey, as CITI Administrator, at (208) 282-2179 /

Which policy applies?    

Conflict of Interest in Sponsored Projects ISUPP 7070

This policy should not be confused with other ISU policies that refer to conflicts of interest for circumstances involving other than externally funded projects.