The Public Health Service (PHS) requires disclosure of significant financial interests by investigators who participate in PHS-funded research either directly or by subaward. Other agencies have adopted the PHS requirements. For more information, see PHS Financial Disclosure Guidance.


Proposal Stage

At the proposal stage investigators must fill out Conflict of Interest screening questions in Phoebe Proposal.

If disclosure is required but the questions are not available in Phoebe, your Sponsored Projects Office Contract and Grant Officer (SPO CGO) will let you know. You will need to complete the PHS Financial Interest Screening Questions Form and upload it in Phoebe.

Note: If an investigator provides any “yes” responses to the screening questions, the investigator will be required to complete the PHS Financial Disclosure Form and email it to their SPO CGO prior to the award being released.

Subrecipients: If subrecipients are included in your proposal, see SPO subrecipient commitment form instructions for conflict of interest requirements. Note: A subaward cannot be issued to a subrecipient that does not have a PHS compliant COI policy in place.

Award Stage

If an investigator provides any “yes” responses to the screening questions, the investigator will be required to complete the PHS Financial Disclosure Form and email it to their SPO CGO prior to the award being released.

If the Phoebe responses were all “no,” then nothing more is required unless the responses to the screening questions were obtained more than 12 months prior to award receipt. Your SPO CGO will let you know if you need to provide an updated PHS Financial Interest Screening Questions Form.

Training: All Investigators are required to take PHS-compliant training prior to engaging in PHS-funded research.

During Life of Award

Investigators must complete a PHS Financial Interest Screening Questions Form at the Progress Report stage or annually and submit it by email their SPO CGO.

If the PHS Financial Interest Screening Questions Form responses included a “yes” response, then the investigator will be required to complete the PHS Financial Disclosure Form and email it to their SPO CGO prior to the award being released.

Investigators must disclose new Significant Financial Interests within 30 days of acquiring the new interest by submitting a PHS Financial Disclosure Form by email to their SPO CGO.

Training: All Investigators are required to take PHS-compliant training while engaging in PHS-funded research.


Forms

NOTE: Please use Adobe Acrobat or Reader to fill out PDF forms. (If you have difficulty filling out a form, please download the form to a local computer before filling it out.)


Resources