NEW PHS Agency Conflict of Interest Requirement

Effective August 24, 2012 U.S. Public Health Service (PHS) amended its Financial Conflict of Interest (FCOI) Regulation. Clemson University has implemented a new process in order to comply with the new PHS regulation. All investigators are required to complete a disclosure form and complete the Conflict of Interest training. PHS defines "Investigator" as the project director or Principal Investigator and any other person, regardless of title or position, who is responsible for the design, conduct, or reporting of research. (Keep in mind that investigator is broadly defined so that it may include any CU personnel, post-doctoral associates, and students.)

If you plan to apply for funding from a PHS (directly or flowing thru another agency) or have current PHS funding or plan to ask for no cost extension of an existing PHS award, you must comply with the new FCOI Regulations.


Each Investigator must complete training prior to engaging in research related to any PHS-funded grant or contract and at least every four years, and immediately under the following circumstances:

  • Institutional FCOI policies change in a manner that affects Investigator requirements; An Investigator is new to Clemson University; or
  • Clemson University finds an Investigator noncompliant with CU’s COI policy or management plan.

Disclosure Form