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Financial Conflicts of Interest (COI) in Sponsored Projects

Why wonder about COI?

In order to maintain accreditation, our qualifications to receive sponsored funding, to attract both academic and private sector partnerships to ISU.

We provide access to the documented processes that when completed ensure employees involved in research disclose any significant financial interests that may represent an actual or potential conflict of interest related to their sponsored projects (ex: grants).

Your cooperation with these steps meets the requirements of specific federal agencies:

  • U.S. HHS - Public Health Service (PHS)
  • National Institutes of Health (NIH)

Having even a few sponsored projects from NIH, for example, means that all personnel at ISU must participate to some degree in COI process, for us to qualify for funding.

COI Process

1. Annual COI Disclosures –

Whether or not the Investigator has a significant financial interest, reimbursed or sponsored travel or other matter that may represent Financial Conflicts of Interest (FCOI) to report, you must participate to receive funding.

  • Who?  Faculty members, students & everyone acting, or planning to act, as Investigators (PIs/CoPIs or Key Personnel) on sponsored projects.
  • When?  During your proposal phase.
  • Where?  Use Cayuse - it's part of your proposal process. For CoPIs, Key Personnel -- certain sponsors (NIH, PIH, CDC) require your answers to the same questions.  These are emailed, the responses reviewed, the award funding released once all disclosures have been completed.

Annual Disclosure Reminders - Even when not required by a sponsor, ROC may still prompt the Lead PI, CoPIs, etc to submit COI answers.  This allows ISU to demonstrate that all Investigators have participated.

ROC reviews the responses to make an informed judgment about each. If appropriate, an arrangement is made for appropriate oversight, limitations, or prohibitions on a disclosed activity.  

Definition of Key Personnel/Investigators:

Key Personnel/Investigator means any person, regardless of title, position, or employment status who is responsible for the design, conduct, or reporting of research, instruction, or service at, on behalf of, or in collaboration with ISU.  

It is the responsibility of the PI on an award to disclose their Key Personnel.











See also: Glossary

for Research Conflict of Interest 

2. Related Conflict of Interest tasks - CITI on-line COI Modules

Some award/grant sources, such as PHS, require Investigators to complete both

  • Financial COI disclosures, and
  • Conflict of Interest training with verification.

This no-cost training is found at CITI online training.

Investigators proposing projects for funding by a sponsor that requires COI training will receive email notices from ROC.  Release of funds occurs once the CITI COI modules are completed -- ROC receives a completion notice automatically.

The COI modules can be reached through 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.
CITI automatically contacts you by e-mail 90 days prior to the expiration date of your course certification.
Questions about CITI? Contact Tom Bailey at (208) 282-2179 /

Questions about the COI training requirement? Contact Deb Easterly,(208) 282-2618/

Please use your email to ensure your training notices are delivered to ROC.

Which policy applies?        

ISU Policy 7070 Conflict of Interest in Sponsored Projects.

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

Research Outreach & Compliance  (ROC)

Contact Our Office:

Deb Easterly
Assistant Vice President for Research Outreach & Compliance
Phone: (208) 282-2618
Serving as ISU's
Research Integrity Officer
Export Control Officer   
Physical Address:
Business and Technology Center
1651 Alvin Ricken Drive, Room 107
Pocatello, ID 83201

Mailing Address:
921 S. 8th Ave., Stop 8046
Pocatello, ID 83209-8046


921 South 8th Avenue
Pocatello, Idaho, 83209
(208) 282-4636

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