Georgetown Research Services
Georgetown Research Services

Financial Conflict of Interest

Georgetown campus viewed from above the Potomac River

The Georgetown University Financial Conflicts of Interest (FCOI) Policy (FCOI Policy) protects the objectivity and integrity of the work of Georgetown University and its individual faculty and staff members. The Policy is designed to ensure that faculty and staff members identify, disclose, and appropriately manage or eliminate situations in which their personal or familial interests might otherwise compromise or appear to compromise their objectivity as teachers, researchers, or administrators.

An effective conflict of interest policy helps both to safeguard the work and reputations of University faculty and staff members and to ensure the University’s compliance with federal and other regulatory requirements relating to conflicts of interest.

The FCOI Policy requires covered individuals to disclose certain financial interests and outside relationships related to their University responsibilities on at least an annual basis, and to update their disclosures if circumstances change.

The University is responsible for reviewing disclosures and managing, reducing, or eliminating identified conflicts. In the context of research, the University must meet applicable sponsor COI requirements and COI reporting obligations where applicable. Georgetown’s Senior Director, ORO is the designated institutional official for COI determinations related to research.

Certain federal research sponsors have specific and additional requirements related to COI training, disclosure, review, and reporting. Georgetown meets applicable sponsor requirements through its FCOI Policy and policy appendices, distinct sponsor-specific COI policies, and/or internal procedures.

For individuals involved in externally-sponsored research (except for PHS and DOE, see below), the timing for disclosure requirements and the definition of significant financial interest and what must be disclosed is outlined in Appendix B of the FCOI Policy.

All “Investigators” (individuals involved in the design, conduct, or reporting of research) must update their disclosures within 30 days of discovering or acquiring a new significant financial interest (as defined in the FCOI Policy).

PHS researchers and DOE researchers are subject to certain additional and/or distinct requirements, as noted in the sections below.

For individuals involved in Public Health Service (PHS) research, the FCOI Policy applies. Specific to PHS researchers, the definition of significant financial interest and what must be disclosed is outlined in Appendix C of the FCOI Policy.

Investigators involved in research funded by the PHS (e.g., NIH, NCI, CDC, FDA, and other organizations abiding by PHS COI regulations) must undergo COI prior to engaging in research and every 4 years. Georgetown uses CITI for meeting PHS COI training requirements; refer here for information on CITI COI training.

For individuals involved in Department of Energy (DOE) research, the FCOI Policy applies.

Specific additional training, disclosure, and reporting requirements also apply to DOE researchers in order to comply with the DOE’s regulations regarding Conflict of Interest and Conflict of Commitment.

Georgetown has instituted an interim DOE-Specific Conflict of Interest and Conflict of Commitment Policy to comply with the new DOE regulations (effective 8/17/26) and created a key information sheet (available here) for DOE researchers.

For researchers submitting applications for DOE research, key additional requirements include:

  • Completion of a DOE Project-Specific Disclosure Form to Georgetown prior to application submission is required in order to provide information on actual, potential, or apparent financial conflicts of interest (FCOI), organizational conflicts of interest (OCI), and conflicts of commitment (COC)
    • JORA will facilitate collection of the DOE-specific disclosure form by “covered individuals” involved in DOE proposals
    • ORO will perform the required review, and identify any required sponsor reporting obligations, prior to application submission
  • Disclosures of new interests and relationships meeting DOE criteria for disclosure must occur within 15 days.
    • Researchers should notify ORO to update a previously submitted DOE project-specific disclosure form
  • COI training is required before proposal submission and every 2 years
    • Georgetown’s Research Security Training in GMS (training already required prior to application submission and annually for DOE researchers) meets the conditions for the DOE COI training, so no additional / separate COI training is needed for DOE researchers if your Research Security training is complete and current

For more information on Georgetown’s DOE-specific Conflict of Interest and Conflict of Commitment policy and procedures, contact Julia Zipper in the Office of Research Oversight: julia.zipper@georgetown.edu.

For individuals involved in NASA research, the FCOI Policy applies. In addition to its application of Appendix B of the FCOI Policy, Georgetown has procedures in place to facilitate compliance with NASA’s COI Policy (section 29.7).

Frequently Asked Questions

Who is an Investigator?

Anyone responsible for the design, conduct, or reporting of research, regardless of title or position. This includes:

If you have any doubts about whether you could be classified as an “investigator,” please contact Nabeel Qureshi, Julia Zipper or Lila Sisbarro.

What are “University Responsibilities”?

“University Responsibilities” include professional responsibilities on behalf of the University, including, but not limited to

What is a Financial Interest?

A financial interest is anything of monetary value, related to an investigator’s University Responsibilities, whether or not the value is readily ascertainable, in any of these categories:

For the full definition of a “significant financial interest,” visit Appendix B and Appendix C of the Georgetown University Financial Conflicts of Interest (FCOI) Policy.

A financial interest DOES NOT include:

What is a COI or Financial Conflict of Interest (FCOI)?

Generally speaking, a Conflict of Interest (COI) exists if a COI Officer determines that an individual’s outside financial interests or relationships intersect with and could impact or bias (or appear to impact or bias) the objectivity of an individual’s University activities.

A Financial Conflict of Interest (FCOI) exists when the institution’s designated official(s) reasonably determines that an investigator’s significant financial interests could directly and significantly affect the design, conduct, or reporting of research. The institution is required to review each Investigator SFI disclosure to determine if a SFI: could directly and significantly affect the design, conduct, or reporting of the research. Georgetown’s Senior Director, ORO is the designated institutional official for COI determinations related to research.

Where Do I File a Conflict of Interest Disclosure Form?

Georgetown University Employees (All Campuses)

All full-time faculty, many full-time staff, investigators on sponsored research projects and IRB protocols (including study team members) employed by Georgetown University, regardless of campus, must complete a conflict of interest disclosure in GU-PASS (or update their GU-PASS disclosure if their circumstances have changed since the disclosure was last completed).

MedStar Health Physicians and Employees

MedStar employed physicians with a Georgetown University faculty appointment complete a conflict of interest disclosure in MedStar’s COI-Smart system. ORO has access to applicable disclosures in COI-Smart to perform required COI reviews.

What Happens After I File a Disclosure Form?

The University is responsible for reviewing disclosures and managing, reducing, or eliminating identified conflicts. Disclosures are reviewed by the Conflict of Interest Officer, who will determine whether or not it includes an actual or potential conflict of interest and, if so, what action is required to manage the situation appropriately. The Conflict of Interest Officer may request additional information from an employee in order to make these determinations. In the case of an identified conflict, the Conflict of Interest Officer may work with the faculty member or staff member to create an appropriate conflict management plan. The University is responsible for reviewing disclosures and managing, reducing, or eliminating identified conflicts. In the context of research, the University must meet applicable sponsor COI requirements and COI reporting obligations where applicable. Georgetown’s Senior Director, ORO is the designated institutional official for COI determinations related to research.

How Do I Complete COI Training?

Investigators who receive Public Health Service (PHS) funding (and funding from other agencies that abide by PHS COI regulations) must undergo conflict of interest (FCOI) training before engaging in the funded research. To complete the training, visit our FCOI training page for instructions.

What Agencies are Part of the Public Health Service (PHS)?

PHS includes the federal agencies and cooperative groups listed below:

Cooperative GroupsALLIANCE, ACRIN, ACSOG
CALGB, COG
ECOG, EORTC
GOG
NCICA, NCCTG, NSABP
RTOG
SWOG
Dept. of Health & Human Services (HHS)Agency for Healthcare Research and Quality (AHRQ)
Agency for Toxic Substances and Disease Registry (ATSDR)
Centers for Disease Control (CDC)
Food and Drug Administration (FDA)
Health Resources and Services Administration (HRSA)
Indian Health Services (IHS)
Office of Global Affairs (OGA)
Office of the Assistant Secretary for Health (ASH)
Office of the Assistant Secretary for Preparedness and Response (ASPR)
Substance Abuse and Mental Health Services Administration (SAMHSA)
National Institutes of Health (NIH)NIH Office of the Director (OD)
National Cancer Institute (NCI)
National Eye Institute (NEI)
National Heart, Lung, and Blood Institute (NHLBI)
National Human Genome Research Institute (NHGRI)
National Institute on Aging (NIA)
National Institute on Alcohol Abuse and Alcoholism (NIAAA)
National Institute of Allergy and Infectious Diseases (NIAID)
National Institute of Arthritis and Musculoskeletal and Skin Diseases (NIAMS)
National Institute of Biomedical Imaging and Bioengineering (NIBIB)
Eunice Kennedy Shriver National Institute of Child Health and Human Development (NICHD)
National Institute on Deafness and Other Communication Disorders (NIDCD)
National Institute of Dental and Craniofacial Research (NIDCR
National Institute of Diabetes and Digestive and Kidney Diseases (NIDDK)
National Institute on Drug Abuse (NIDA)
National Institute of Environmental Health Sciences (NIEHS)
National Institute of General Medical Sciences (NIGMS)
National Institute of Mental Health (NIMH)
National Institute on Minority Health and Health Disparities (NIMHD)
National Institute of Neurological Disorders and Stroke (NINDS)
National Institute of Nursing Research (NINR)
National Library of Medicine (NLM)
Center for Information Technology (CIT)
Center for Scientific Review (CSR)
Fogarty International Center (FIC)
National Center for Complementary and Alternative Medicine (NCCAM)
National Center for Advancing Translational Sciences (NCATS)

Questions or Concerns?

For questions about policies, procedures, or training, please contact: