PHS Funded Researchers:
Avoid Retrospective Reviews of your Research!

The Continuing Obligation to Disclose new Significant Financial Interests, Business Interests, and Reimbursed or Sponsored Travel

Investigators conducting research funded by one of the Public Health Service (PHS) agencies have 30 days to disclose on a REPA any new significant financial interests and business interests that they have discovered or acquired (e.g. through purchase, marriage, or inheritance).

This reporting requirement includes the occurrence of any reimbursed or sponsored travel related to your University responsibilities or expertise, with the exception of travel paid for by a Federal, state, or local government agency, an Institution of higher education (an accredited public or nonprofit educational institution in the United States), an academic teaching hospital, a medical center, or a research Institute that is affiliated with an Institution of higher education. Annual travel expenses paid by an entity that in the aggregate are $5000 or less need not be reported.

Once disclosed on a REPA, the University has 60 days to review the disclosure, determine if a conflict of interest exists, and if so, to implement a management plan on at least an interim basis.

Investigators are defined by the PHS as the project director, principal investigator, and any other person, regardless of title or position, who is responsible for the design, conduct, or reporting of research funded by the PHS, or proposed for such funding, which may include, for example, collaborators or consultants.

Failure to identify or manage a conflict of interest in a timely fashion requires the University to complete a retrospective review of the investigator’s activities and the PHS-funded research project to determine whether any PHS-funded research, or portion thereof, conducted during the time period of the noncompliance was biased in the design, conduct, or reporting of the research.

Investigators can avoid retrospective reviews by making timely and complete disclosures of their significant financial interests (SFI) and business interests (BI) on the REPA. If after filing your annual REPA you acquire a new SFI or BI, or accept reimbursed or sponsored travel expenses, you should click on the “Fill Out a REPA Form” button on the COI Homepage, select “change in circumstance” as the reason for filing, and disclose the new information accordingly: