Conflict of Interest

Reviews existing and new administrative requirements imposed by federal regulations and program officers related to conflicts of interest (individual and institutional). The emphasis should be on harmonization of requirements across federal agencies, reduction of redundancies and identifying good practices.


Compliance Issues Checklist for Subawards Issued to Faculty Owned Companies
Case Studies
Risk Analysis Matrix and Model Management System

2018 - 2019 OCI Working Group "Resource Documents"

Organizational Conflict of Interest Training deck
Sample OCI review process (courtesy of University of Pittsburgh)
Sample language to insert for peer review vs. proposal OCI (courtesy of Stanford)
Sample of NASA COI mitigation plan (courtesy of Princeton)
Sample of NASA COI mitigation plan (courtesy of UCLA)

Archived Documents

Notes from September 2019 Meeting
Penn State Draft COI Training
Invitation to join FDP Clearinghouse for FCOI Compliance
NIH COI Resources
Notes from Jan. 2016 Meeting

For subrecipients not yet having their own FCOI Policy

FDP Model Financial Conflict of Interest Policy and Model Disclosure Form (for potential adoption by subrecipients not yet having their own FCOI policy)

The model policy and form listed below is intended to assist subrecipients who wish to create their own Financial Conflict of Interest policy. This model policy has been developed by members of the FDP who are familiar with PHS Financial Conflict of Interest requirements; however, subrecipients are independently responsible for conducting their own review to ensure that this model or an adapted version is compliant with PHS policy. Tools are available on the NIH web site to assist institutions with this process, including a Checklist for Policy Development at: and a FCOI tutorial at:

FDP Model Policy
FDP Model Report Form

Subcommittee Members

Mary R Lee, Co-Chair Stanford University
Diane Dean, Co-Chair National Institutes of Health