Financial Conflict of
INTEREST
CF NEUROMEDICS, Inc. Financial Conflict of Interest (FCOI) Policy
Revised Date: July 29th , 2025
1. Purpose
This Financial Conflict of Interest (FCOI) Policy is established to comply with the United
States National Science Foundation (NSF) and National Institutes of Health (NIH)
regulations on Conflict of Interest, specifically the requirements outlined in the NSF
Proposal & Award Policies & Procedures Guide (PAPPG) and NIH FCOI Policy. The purpose
of this policy is to ensure objectivity in research and to identify and manage financial
conflicts of interest that could directly and significantly affect the design, conduct, or
reporting of NSF or NIH-funded research.
2. Applicability
This policy applies to all Investigators (as defined below) who are planning to participate in,
or are participating in, NSF- or NIH-funded research activities at CF NEUROMEDICS, Inc.
3. Definitions
• Investigator: Any individual who is responsible for the design, conduct, or reporting of
NSF- or NIH-funded research or educational activities, which may include the PI, Co-PIs,
senior/key personnel, and any other individuals designated by CF NEUROMEDICS, Inc.
• Significant Financial Interest (SFI):
- A financial interest consisting of one or more of the following:
- Income or payment of services from a publicly traded entity exceeding $10,000 in
the past 12 months or holding equity interest valued over $10,000 or 5% ownership.
- Income or equity interest from a non-publicly traded entity exceeding $10,000 or
any ownership interest.
- Intellectual property rights and interests (e.g., patents, copyrights) upon receipt of
income related to such rights.
- Exclusions: Salary, royalties, or other remuneration from CF NEUROMEDICS, Inc.; income
from seminars, lectures, or teaching sponsored by government or non-profit entities;
mutual funds or retirement accounts.
• Financial Conflict of Interest (FCOI): An SFI that could directly and significantly affect the
design, conduct, or reporting of NSF-funded research.
4. Disclosure Requirements
Investigators are required to disclose all SFIs:
- At the time of proposal submission to the NSF or NIH;
- At least annually during the period of the NSF or NIH award;
- Within 30 days of acquiring or discovering a new SFI.
Disclosures shall be submitted to the designated CF NEUROMEDICS, Inc. Conflict of Interest
Official (COIO).
5. Review and Management
CF NEUROMEDICS, Inc.’s COIO will review all SFI disclosures to determine if a Financial
Conflict of Interest exists. If an FCOI is identified, a management plan will be developed,
implemented, and monitored to ensure that the conflict does not compromise the
objectivity of the research.
Possible management strategies may include:
- Public disclosure;
- Modification of the research plan;
- Monitoring by independent reviewers;
- Reduction or elimination of the financial interest.
6. Enforcement
Failure to disclose SFIs or comply with the management plan may result in disciplinary
action, up to and including termination of employment or removal from the NSF- or NIH-
funded project. CF NEUROMEDICS, Inc. will also notify the NSF or NIH if an FCOI is not
managed as required.
7. Record Retention
CF NEUROMEDICS, Inc. will maintain records of all disclosures, determinations, and
management plans for at least three years from the date the final expenditure report is
submitted to the NIH, or from other dates specified in 45 CFR § 75.361, where applicable.
8. Training
All Investigators must complete FCOI training:
- Prior to engaging in NSF- or NIH-funded research;
- At least once every four years;
- Immediately if this policy is revised, an Investigator is new to CF NEUROMEDICS, Inc., or if
non-compliance is found.
9. Public Accessibility
This policy is publicly available on CF NEUROMEDICS, Inc.’s website at:
https://www.cfneuromedics.com/
Information concerning identified FCOIs held by senior/key personnel will be made
publicly accessible on CF NEUROMEDICS’s website or provided in writing within five (5)
calendar days upon request. This information will:
- Include the minimum elements required by regulation;
- Be updated at least annually on the website;
- Be updated within 60 days of any newly identified FCOI;
- Remain publicly available for at least three (3) years from the date of the most recent
update.
10. Reporting to NIH
CF NEUROMEDICS, Inc. will submit required Financial Conflict of Interest (FCOI) reports to
the NIH as follows:
- Prior to the expenditure of funds;
- Within 60 days of identifying a Financial Conflict of Interest for an Investigator who is
newly participating in the project;
- Within 60 days of discovering a new or newly identified FCOI for an existing Investigator;
- At least annually (at the same time as the annual progress report or at extension) to
provide the status of the FCOI and any changes to the management plan;
- Following a retrospective review, to update a previously submitted report if appropriate.
11. Retrospective Review and Mitigation Reporting
If CF NEUROMEDICS, Inc. identifies a significant financial interest that was not disclosed in a
timely manner or not previously reviewed, the institution will conduct a retrospective
review within 120 days. If the review determines that the research was biased, CF
NEUROMEDICS, Inc. will promptly notify the NIH and submit a Mitigation Report as
required.
12. Subrecipient Requirements
When CF NEUROMEDICS, Inc. carries out NIH-funded research through a subrecipient, CF
NEUROMEDICS, Inc. will establish a written agreement to determine whether the
subrecipient will follow its own FCOI policy or CF NEUROMEDICS’s policy.
- If following the subrecipient’s FCOI policy, the agreement will include a certification that
the policy complies with 42 CFR Part 50 Subpart F.
- If following CF NEUROMEDICS, Inc.'s FCOI policy, the agreement will require subrecipient
Investigators to submit disclosures to CF NEUROMEDICS, Inc. in sufficient time to enable
reporting to NIH.
All subrecipient FCOIs must be reported to NIH by CF NEUROMEDICS, Inc. according to the
timelines outlined above.