Frequently Asked Questions

The financial interest disclosure module is separate from our grants database, so grants are only in there if Grant Administrators enter them or PI’s enter them.

Grant admins pre-fill grant information in disclosure forms for PI’s this way:
1) Go to
2) Click on “Manage Projects”
3) Click on “+Add Project”, in the top left corner
4) After submitting, grant admins then click on “Send Invitation to PI”, in the right most column of the “Manage Projects” page
5) Then when PIs sign in, they see the project with an “INVITED to disclose” status.

PI’s start new project disclosures this way:
1) Go to
2) Click on “My Financial Disclosure Forms”
3) Click on the “+New Disclosure” link.

Prior disclosed financial information will pre-fill in any case.

Click on this link for Tips, Tricks and Troubleshooting

The project director or principal investigator, and anyone who is responsible for the design, conduct, or reporting of research (i.e., “investigators”), including, at minimum, all those designated as senior/key personnel in the grant application, if applicable.

The Principal Investigator (or Project Director), upon consideration of the individual’s role and degree of independence in carrying out the work, will determine who is responsible for the design, conduct, or reporting of the research. It is the assessment of an individuals’ responsibility, rather than their title, that is key.


As stated under the question above, anyone who is responsible for the design, conduct, or reporting of research will disclose. The Principal Investigator (or Project Director), upon consideration of the individual’s role and degree of independence in carrying out the work, makes this determination. It is the assessment of an individuals’ responsibility, rather than their title, that is key.

Also, all investigators, even those that come from outside institutions, must disclose and train using BU forms and training. However, this specifically excludes those who are working under a subaward agreement at an institution with its own research conflict of interest policy, as long as the subaward agreement and letter of intent specifically state that their home institution’s policies on conflicts of interest will rule.

For all BMC research and PHS-funded BU research, investigators are required to disclose financial interests (and those of the investigator’s spouse and dependent children) that reasonably appear to be related to the investigator’s institutional responsibilities, regardless of whether they are related to a specific research project or not.

(1) no later than at the time of application for research;

(2) within 30 days of discovering or acquiring (e.g., through purchase, marriage, or inheritance) a new significant financial interest; and

(3) at least annually during the period of award. A targeted group of individuals in the research community will be asked to submit annual disclosures due to their participation in research in the past.

Forms may be submitted one of two ways:

Send all MS Word/Adobe forms to:


Fax: 617-414-4738

Conflicts of Interest
Research Compliance office
85 East Newton Street, Suite M-810
Boston, MA 02118

See this chart for Covered Research at BU and BMC for Financial Interest Disclosure

If your project fits into the definition of research provided, and isn’t one of the exceptions, financial interest disclosure is required.

Yes. If you are doing work under a grant administered by Boston University or Boston Medical Center (with some exceptions for BU grants that are not sponsored by a Public Health Service agency), you need to complete our financial conflict of interest (FCOI) training. We do not accept CITI training as a substitute, nor training completed at your home institution.

The purpose of the training is to teach you how to follow BU and BMC FCOI policies, and every institution’s FCOI policy is slightly different.

If you are doing work under a subaward, and your institution has chosen to follow BU or BMC’s FCOI policy, you will also be asked to complete our institutional training.

The training consists of 15 PowerPoint slides and 10 quiz questions. You need a score of 80 to pass and you have an unlimited number of tries to achieve that score.

In order to complete our training, which is hosted in Blackboard, you will need a Boston University ID. Our Information Services & Technology group will reach out to you about setting that up and then enrolling you in the Blackboard course so you can go in and complete the training. You will receive an email that looks similar to the following:

Hello from Boston University Research Compliance (financial conflicts of interest unit),

As part of a recent submission for a grant in relation to research, you are being asked to complete online financial interest disclosure training, in accordance with Federal Law 42 CFR Part F, Subpart 50 and Boston University (BU) and Boston Medical Center (BMC) policies.

Boston University Information Services & Technology (IS&T) will be in touch with you, providing a unique link for you to click on so you can create your Boston University user name.

After creating a BU user name, you should notify IS&T as they will request you to do in their email to you. They will then enroll you in the BU Blackboard training site. There you will find the Financial Interest Disclosure Training under “courses in which you are enrolled.”

The training is a series of PowerPoint slides and a 10-question quiz. It takes about 10 minutes to complete and a score of 80 is required to pass. You are permitted an unlimited number of tries to achieve this score.

If you have any questions, please email or call:

Sarah Porter
Compliance Specialist, Conflicts of Interest
Research Compliance

If you do not complete the training, we may hold disbursement grant funds or notify the sponsor.

The institutional policy applies to financial interests held by Boston University as an institution (not including BMC), as well as the financial interests of key individuals* (including his or her spouse and dependent children) at Boston University. Conflicts of interest under this policy are reviewed and managed similarly to financial conflicts of interest held by individual researchers. Principal investigators are notified if their project will need to undergo committee review, if BU as an institution has a significant financial interest in the research they are conducting.

*Key individuals include, but are not limited to: University presidents, provosts (including associate and assistant provosts), vice presidents (including associate and assistant vice presidents), deans (including associate and assistant deans), department chairs, division chiefs, center and institute directors, technology transfer officers, and chairs of the Institutional Review Board, Institutional Biosafety Committee, Institutional Animal Care & Use Committee, Stem Cell Research Committee, and Patent Committees.

For Research that involves Subrecipients at other Institutions, Subrecipients have 2 options:

Option 1: Certify that its FCOI policy is compliant with 42 CFR Part 50 and 45 CFR Part 94 and that they will be responsible for ensuring the Institution and its Investigators comply with the federal regulations.  Under this option, Subrecipients must report to BU, as the awardee Institution, any identified FCOI within 10 business days of the management plan agreement with the Subrecipients Investigator, but no later than 45 days after identification of the FCOI by the Subrecipient.

Option 2: Follow BU’s FCOI policy. If BU’s policy is used, the Subrecipient must ensure that its Investigators disclose to BU by the time of submission of the grant application by BU or at the time the Subrecipient signs an institutional letter of support if during an on-going award grant or contract. For an awarding agency that follows PHS FCOI rules, Subrecipient Investigators will also need complete BU’s Financial Interest Disclosure Training. Instructions will be sent after the disclosure form is received.

Absolutely! Please contact us to schedule a training session.