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Step 2: FCOI Certification Review

COI Office Review

All certifications received indicating no outside Signification Financial Interests related to University of Houston research undergo an administrative review within the COIC office. A memo is generated acknowledging that the investigator has reported no potentially conflicting financial interests; this memo is sent to the investigator, and archived by the COI Office.

Certifications submitted with associated disclosures are first reviewed in the COI Office for completeness. Based on content, office staff may request additional information or clarification from the investigator prior to routing the disclosure to the Conflict of Interest Committee for review.

At this time, the COI Office will also check to make sure all Public Health Service (PHS) funded investigators have completed required online training for COI. Online training is provided through the Collaborative Institutional Training Initiative (CITI), of which UH is a member. FCOI modules 1 and 2 must be completed prior to utilizing PHS funds and at least once every four years. Refer to these instructions (PDF) for how to access the FCOI modules. If your COI CITI training is expiring, you should take the COI CITI Refresher training. Instructions for the refresher modules are here

Conflict of Interest Committee (COIC) Review

All disclosures are placed on an agenda for review at a convened COIC meeting.  A primary and a secondary committee reviewer are assigned to review the disclosure and associated documents, and present the information to the full committee. Upon committee discussion, a determination will be made regarding whether or not a conflict exists between the significant financial interest and the research that could be perceived to bias the design, conduct or reporting of the research. If a conflict exists, the investigator will be asked for a plan (or an updated plan, if necessary) to manage the conflict.

Note: If not enough information is provided regarding the financial interest or how it may appear to conflict with the research, the disclosure will be tabled and a request for further clarification made. This will delay a final determination until the committee conducts additional review at a subsequent meeting.