Financial Conflicts of Interest (FCOI) in research may occur when outside financial interests compromise, or have the appearance of compromising, the professional judgment of a researcher when designing, conducting, or reporting research. FCOIs are not inherently bad and do not always lead to biased behavior.

BU has two policies that address conflicts of interest in research:

Members of the research community should review these policies so they understand their responsibilities as they pertain to federal requirements and university policy.

Effective 8/7/17, Boston Medical Center (BMC) Investigators working on BMC Research must disclose their Significant Financial Interests, or SFIs, through the BMC Compliance Department’s web based system, COI-Smart.

Please contact BMC’s Compliance Department at if you require access and provide your name, email address, department and section (e.g., Pediatrics/Pediatric Infection Diseases; Medicine/General Internal Medicine; Medicine/Cardiology).

After 8/7/2017, any BMC Investigator that inadvertently receives an annual disclosure request from BU for a BMC Research project should notify BMC’s Compliance Department at to have BU remove the BMC Research project from BU’s system.

BU Investigators working on BU Research Projects should continue to follow the Disclosure Procedures below.

Disclosure Procedures

Step One: Complete a Financial Interest Disclosure

  • BMC Investigators working on BMC Research must disclose their SFIs through the BMC Compliance Department’s web based system, COI-Smart.  Please contact BMC’s Compliance Department at if you require access

Step Two: Complete Financial Interest Disclosure Training

  • Investigators engaging or planning to engage in Public Health Service (PHS) Funded Research must complete financial conflict of interest training on investigator responsibilities prior to engaging in PHS-Funded Research and at least once every four (4) years.

Step Three: FCOI Committee Review

  • When the Committee identifies a financial conflict of interest, it will submit a proposed management plan to the Associate Vice President for Research Compliance (AVPRC). The investigator will have an opportunity to review and comment on the management plan before it is sent to the AVPRC.

Step Four: Management Plans

  • The AVPRC will make the final determination on how to manage the FCOI and will accept, reject, or modify the Review Committee’s recommendation.
  • The COI Program will send the final decision to the investigator for review and signature.