HIRE Strategies, LLC
Financial Conflict of Interest (FCOI) Policy
Effective Date: December 19th, 2025
- Purpose
HIRE Strategies, LLC (“HIRE Strategies”) is committed to maintaining the highest standards of integrity, transparency, and objectivity in all work performed under federally funded contracts, grants, cooperative agreements, and subcontracts.
This Financial Conflict of Interest (FCOI) Policy is established to ensure compliance with:
- 42 CFR §50 Subpart F (Grants and Cooperative Agreements)
- 45 CFR §94 (Contracts)
- Public Health Service (PHS) requirements
- RTI International subcontractor requirements
The purpose of this policy is to identify, manage, reduce, or eliminate financial conflicts of interest that could directly and significantly affect the design, conduct, or reporting of PHS-funded research or contract work.
- Applicability
This policy applies to:
- All Investigators, defined as any individual responsible for the design, conduct, or reporting of work performed under a PHS-funded project or RTI subcontract, regardless of title or position.
- Employees, contractors, consultants, or collaborators engaged by HIRE Strategies who meet the Investigator definition.
- Definitions
Investigator
Any individual, regardless of title or role, who is responsible for the design, conduct, or reporting of PHS-funded research or contract work.
Significant Financial Interest (SFI)
A financial interest consisting of one or more of the following interests of the Investigator (and their spouse and dependent children) that reasonably appears to be related to the Investigator’s institutional responsibilities which may include for example: activities such as research, research consultation, teaching, professional practice, institutional committee memberships, and service on panels such as Institutional Review Boards or Data and Safety Monitoring Boards:
- Publicly traded entities:
Remuneration and/or equity interest exceeding $5,000 in the preceding 12 months. - Non-publicly traded entities:
Any equity interest, or remuneration exceeding $5,000. - Intellectual property:
Income related to patents, copyrights, or licensing agreements. - Sponsored or reimbursed travel related to institutional responsibilities (excluding travel reimbursed by government agencies, academic institutions, or research institutes).
A significant financial interest does not include the following types of financial interests:
- Salary, royalties, or other remuneration paid by HIRE Strategies or a higher tier recipient to the Investigator if the Investigator is currently employed or otherwise appointed by HIRE Strategies or a higher tier recipient, including intellectual property rights assigned to HIRE Strategies or a higher tier recipient and agreements to share in royalties related to such rights;
- Any ownership interest in HIRE Strategies or a higher tier recipient held by the Investigator;
- Income from investment vehicles, such as mutual funds and retirement accounts, as long as the Investigator 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; or
- 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.
Financial Conflict of Interest (FCOI)
A Significant Financial Interest that could directly and significantly affect the design, conduct, or reporting of PHS-funded work.
- Investigator Disclosure Requirements
All Investigators must:
- Disclose all Significant Financial Interests:
- Prior to engaging in PHS-funded or RTI subcontracted work
- At least annually thereafter
- Within 30 days of discovering or acquiring a new SFI
- Submit disclosures using HIRE Strategies’ designated disclosure process.
Failure to disclose may result in corrective action, up to and including removal from the project.
- Review and Determination of FCOI
HIRE Strategies will designate an FCOI Official responsible for:
- Reviewing all SFI disclosures
- Determining whether an SFI constitutes an FCOI
- Developing and overseeing management plans when required
Each disclosure will be reviewed to assess whether the SFI is related to the Investigator’s responsibilities and whether it could directly and significantly affect the funded work.
- Management of Financial Conflicts of Interest
If an FCOI is identified, HIRE Strategies will implement a written management plan, which may include:
- Public disclosure of the conflict;
- Modification of the Investigator’s role or responsibilities;
- Independent oversight or monitoring;
- Divestiture of the conflicting financial interest; or
- Disqualification from participation in affected portions of the project.
Investigators must comply fully with all management plans.
- Reporting to RTI and Federal Agencies
HIRE Strategies will:
- Report identified FCOIs to RTI in a timely manner
- Provide all required details, including management plans, as required under federal regulations
- Submit updated reports for newly identified FCOIs within 60 days
- Investigator Training
All Investigators must complete FCOI training:
- Prior to engaging in PHS-funded or RTI subcontracted work
- At least every four (4) years
- Immediately if:
- This policy is revised;
- An Investigator is new; or
- An Investigator is found non-compliant.
Approved training includes the NIH FCOI tutorial:
https://grants.nih.gov/grants/policy/coi/tutorial2018/story_html5.html
- Record Retention
HIRE Strategies will retain:
- All disclosures
- FCOI determinations
- Management plans
- Related correspondence
for at least three (3) years from the date of final expenditure reporting or as otherwise required by federal regulations.
- Enforcement and Non-Compliance
Failure to comply with this policy may result in:
- Corrective action
- Mandatory training
- Removal from projects
- Contractual remedies
HIRE Strategies will promptly address any identified non-compliance and take appropriate corrective actions.
- Public Accessibility
42 CFR 50.605(a)(5) requires that prior to HIRE Strategies expending any funds under a PHS-funded research project, HIRE Strategies shall ensure public accessibility, via a publicly accessible Web site or written response to any requestor within five business days of a request, of information concerning any significant financial interest disclosed to HIRE Strategies that meets the following three criteria:
- The significant financial interest was disclosed and is still held by an Investigator;
- HIRE Strategies has determined the significant financial interest is related to the PHS-funded research; and
- HIRE Strategies has determined the significant financial interest is a financial conflict of interest.
HIRE Strategies has determined that responding in writing to any requestor within five business days via email or US Mail is the best approach for HIRE Strategies. HIRE Strategies will post the FCOI Official’s contact information on the HIRE Strategies website to allow for requests from the public.
Upon receipt of a public request, the FCOI Official will respond within 5 business days with the following information:
- Investigator’s name;
- Investigator’s title and role with respect to the research project;
- Name of the entity in which the significant financial interest is held;
- The nature of the significant financial interest; and
- The approximate dollar value of the significant financial interest (dollar ranges are permissible: $0-$4,999; $5,000-$9,999; $10,000-$19,999; amounts between $20,000-$100,000 by increments of $20,000; amounts above $100,000 by increments of $50,000), or a statement that the interest is one whose value cannot be readily determined through reference to public prices or other reasonable measures of fair market value.
The FCOI Official will notify the program manager and the Investigator of the request and response.
This policy will also be maintained as a publicly accessible document on the HIRE Strategies website to satisfy federal transparency requirements.
- Policy Contact
Questions regarding this policy should be directed to:
FCOI Official
HIRE Strategies, LLC
2443 Lynn Road, Suite 108
Raleigh, NC 27612
shopson@hire-strategies.com
