It is Hartford HealthCare’s (HHC) policy to preserve the integrity and quality of research at HHC and to maintain public trust in our scientific endeavors by managing actual or perceived conflicts of interest in the conduct of research.  Therefore, all significant financial interests in regards to an investigator’s institutional responsibilities shall be disclosed, reviewed and managed in accordance with the HHC Financial Conflict of Interest in Research Policy.

Investigator is defined as the Principal Investigator (PI) or Project Director (PD) and any other person, regardless of title or position, who is responsible for the design, conduct, or reporting of research administered at HHC.

Training Requirements

All HHC investigators must complete mandatory financial conflict of interest (FCOI) in research training every 4 years through the CITI Program

Instructions to access the CITI conflicts of interest course can be found here.

Please note that new studies and continuations of existing studies will not be approved by the IRB until all mandatory CITI courses, including conflicts of interest, have been completed by all study personnel.

Financial Interests Disclosure

All HHC investigators are required to complete an annual Financial Interests in Research Disclosure form and also have the on-going responsibility to disclose the discovery or acquisition of new significant financial interests within 30 days of the occurring event.  The Research Conflict of Interest Committee (RCOIC) will determine if a conflict exists and, if needed, recommend a management plan for the investigator and his/her related research project(s).

The FCOI in research disclosure process is now administered through REDCap, a web-based application, by the HHC Office of Compliance, Audit and Privacy (OCAP).  If you need a Financial Interests in Research Disclosure form or have questions regarding the policy and procedures, please contact:

Rhonda Longo, Compliance & Education Research Manager
Office of Compliance, Audit & Privacy (OCAP)
Office: 860-972-7065
Fax: 860-696-8130

Additional Resources 

HHC FCOI in Research Policy

HHC FCOI Policy - Frequently Asked Questions (FAQs)

FCOI In Research Process Overview Slides

Public Health Service FCOI Request Form

Laws & Regulations

2011 Public Health Service (PHS) Regulations:

National Institutes of Health (NIH) – FCOI Web Page