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Home / FAQs / Who is subject to FCOI disclosure rules?

Who is subject to FCOI disclosure rules?

In the summer of 2012, as a result of several changes in federal law and other factors, the Texas A&M University system adopted new policies in regards to disclosure and training about Financial Conflict of Interest (FCOI) for research Investigators.

For questions about the TAMUS policy, consult: System Policy 15-01-03, Financial Conflicts of Interest in Sponsored Research.

At that time a mechanism was needed to identify employees that were subject to the new disclosure and training requirements.  It was determined that the following employees would be subject to these new requirements:

  • Employees with titles that were marked as PI eligible in the TAMUS payroll/HR system (BPP)
  • Faculty members with tenure.
  • Graduate Assistants – Research

This criteria was adopted, but over time it has proved problematic.  Exceptions and over-rides have been implemented by changing employee’s PI Eligible status – often leading to confusion.

In May of 2013 the decision was made to add a new indicator to the official employee records in BPP that would indicate if the employee was subject to the FCOI requirements.

  • Management of this element has moved to the Maestro application.

The flag has initially been set for all employees to be true if:

  • The employee is PI eligible
  • The employee is tenured faculty
  • The employee is a Graduate Assistant – Research

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