Contact Research Integrity and Compliance for assistance. Phone: 512-245-1423 Office: San Marcos Texas Campus - JCK 489
On Monday, August 4, 2025, the Kauli portal will open for submission of Significant Financial Interest (SFI) Annual Disclosures for the 2025–26 academic year. Please note that this year’s disclosure will include a required attestation regarding participation in foreign talent recruitment programs. This attestation, along with associated training, is mandated by federal regulations and complies with the guidelines outlined in GA-48.
Research Conflict of Interest Resources
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What Constitutes a Reportable Significant Financial Interest (SFI)?
Significant Financial Interest (SFI) is defined as a financial interest consisting of one or more of the following interests of the Investigator or the Investigator's Covered Family Members that reasonably appears to be related to the Investigator's institutional responsibilities:
- Remuneration or Equity Interest in a Publicly Traded Entity: A financial interest in which the value of any remuneration received from the entity in the twelve months (12) preceding the disclosure and the value of any equity interest in the entity as of the date of disclosure, when aggregated, exceeds $5,000;
- Remuneration or Equity Interest in a Non-Publicly Traded Entity: A financial interest in which the value of any remuneration received from the entity in the twelve months (12) preceding the disclosure, when aggregated, exceeds $5,000, or when the Investigator holds any equity interest;
- Intellectual Property: Any receipt of income for intellectual property rights and interests (e.g. patents, copyrights);
- Reimbursed or Sponsored Travel: Any reimbursed or sponsored travel in the twelve months (12) preceding the disclosure in which the value (aggregated per entity that reimburses or sponsors the travel) exceeds $5,000. This does not apply to Investigators who do not receive PHS funding; See "SFI Exclusions" below for additional exclusions for travel that is not reportable.
SFI Exclusions: The term Significant Financial Interest (SFI) does not include the following types of financial interests:
- Salary, royalties, or other remuneration paid by TEXAS STATE UNIVERSITY to the Investigator or Covered Family Member if the Investigator or Covered Family Member is currently employed or otherwise appointed by TEXAS STATE UNIVERSITY , including intellectual property rights assigned to TEXAS STATE UNIVERSITY and agreements to share in royalties related to such rights;
- Income from investment vehicles, such as mutual funds and retirement accounts, as long as the Investigator or Covered Family Member does not directly control the investment decisions made in these vehicles;
- Income from seminars, lectures, or teaching engagements sponsored by a federal, state, or local government agency, an institution of higher education as defined at 20 U.S.C. 1001(a), an academic teaching hospital, a medical center, or a research institute that is affiliated with an institution of higher education;
- Income from service on advisory committees or review panels for a federal, state, or local government agency, an institution of higher education as defined at 20 U.S.C. 1001(a), an academic teaching hospital, a medical center, or a research institute that is affiliated with an institution of higher education;
- Travel that is reimbursed or sponsored by a federal, state, or local government agency, an institution of higher education as defined at 20 U.S.C. 1001(a), an academic teaching hospital, a medical center, or a research institute that is affiliated with an institution of higher education; and
- Travel not meeting the exceptions in part (5) above, but is valued at less than $5,000 per entity that reimburses or sponsors the travel.
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FCOI Disclosure Form
The Financial Conflict of Interest Disclosure Form was developed to comply with the 2011 COI regulations. It is fully electronic and accessible at https://txstate.kuali.co/dashboard/
UPP No. 02.02.07 requires covered Individuals to submit a FCOI Disclosure Form at least annually, or within 30 days of discovering or acquiring a new, financial interest related to their university responsibilities.
If you encounter any issues while submitting the FCOI Disclosure Form, please contact Research Integrity and Compliance at 512-245-1423 or r_integrity@txstate.edu
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Conflicts of Interest Training Requirement for NIH and PHS Awards
If you are receiving an award from the NIH or another Public Health Service (PHS) agency, you are required to complete the online “Conflicts of Interest” training module offered through the Collaborative Institutional Training Initiative (CITI). Texas State University subscribes to this nationally recognized program, which features expert-developed content that is regularly updated.
The CITI training is available online 24/7, allowing users to save progress, log in and out of modules, and complete the course at their own pace. The curriculum includes instructional modules followed by short multiple-choice quizzes. Because Texas State subscribes to multiple CITI courses, you will be asked a series of questions to help you enroll in the appropriate Learner Group based on your research activities.
To access the training, visit the CITI Program website and click “LOG IN THROUGH MY INSTITUTION.”
Mandatory Training Requirements: Investigators funded by the NIH, other PHS-compliant agencies, the Department of Energy (DOE), or those with an active Management Plan must complete the “Conflicts of Interest in Research: Disclosure, Management, and Reporting” training module:
Before engaging in any PHS, PHS-compliant agency, or DOE-funded research
At the initiation of a Management Plan (if applicable)
Every three (3) years thereafter
Recommended for Other Investigators: All other investigators are encouraged to complete this training voluntarily, as it provides valuable information and a review of key terms related to research integrity.
Please contact Research Integrity and Compliance (RIC) as soon as you receive a Notice of Award to ensure all NIH and PHS compliance requirements are met in a timely manner.
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Policies
- 2021 PHS Conflict of Interest Regulations, 42 CFR Part 50, Subpart F
- Texas State University UPPS 02.02.07 Researcher Conflicts of Interest in Research and Sponsored Program Activities
- Texas State University UPPS 02.02.08 Conflicts of Commitment in Research and Sponsored Program Activities
- Texas State University UPPS 04.04.06 Outside Employment and Activities
- Texas State University UPPS 01.04.02 Ethics Policy
- Texas State University UPPS 04.04.07 Nepotism and Related Employment
- Texas State University Significant Financial Disclosure Form:
- Texas State University FCOI Training: Conflicts of Interest.
- NIH Conflict of Interest Page:https://grants.nih.gov/grants/policy/coi/
- Summary of Major Changes from 1995 to 2011 COI Regulations:https://grants.nih.gov/grants/policy/coi/summary_of_major_changes.doc
- COGR Principles for Evaluating Conflict of Commitment Concerns in Academic Research updates from September 2021: https://www.cogr.edu/principles-evaluating-conflict-commitment-concerns-academic-research.