Training for Public Health Service Funding

Public Health Service (PHS) and the Office of the Secretary of the U.S. Department of Health and Human Services (HHS) published revised regulations in August 2011. Effective August 24, 2012, additional training in financial conflict of interest is required for PHS funded investigators. To meet this requirement, researchers must complete the course titles “Mini Course on Financial Conflicts of Interest” in the online CITI system.

According to the PHS, “Investigator” means the project director or principal investigator and any other person, regardless of title or position, who is responsible for the design, conduct, or reporting of research funded by the PHS (e.g., NIH), or proposed for such funding, which may include, for example, collaborators or consultants. Institutions should consider the role, rather than the title, of those involved in research and the degree of independence with which those individuals work. When the definition of investigator is limited to titles or designations (e.g., to principal investigators, key personnel, faculty) the risk is that an unidentified FCOI may compromise the research enterprise increases.

Sponsored Projects will not release your account until this additional training is completed. If you have questions, contact Nancy Moody at

Organizations Requiring Compliance with PHS Financial Conflict of Interest (FCOI) Regulations

U.S. Public Health Services (PHS) Agencies:

  1. Agency for Healthcare Research and Quality (AHRQ)
  2. Agency for Toxic Substances and Disease Registry (ATSDR)
  3. Centers for Disease Control (CDC)
  4. Food and Drug Administration (FDA)
  5. Health Resources and Services Administration (HRSA)
  6. Indian Health Services (IHS)
  7. National Institutes of Health (NIH)
  8. Substance Abuse and Mental Health Services Administration (SAMHSA)

Non‐PHS organizations that have adopted the PHS FCOI regulations:

  1. Alliance for Lupus Research
  2. American Cancer Society
  3. American Heart Association
  4. Arthritis Foundation
  5. Susan G. Komen for the Cure

NIH requires that all trainees, fellows, participants, and scholars receiving support through any NIH training, career development award (individual or institutional), research education grant, and dissertation research grant must receive instruction in responsible conduct of research. This policy will take effect with all new and renewal applications submitted on or after January 25, 2010, and for all continuation (Type 5) applications with deadlines on or after January 1, 2011. This Notice applies to the following programs: D43, D71, F05, F30, F31, F32, F33, F34, F37, F38, K01, K02, K05, K07, K08, K12, K18, K22, K23, K24, K25, K26, K30, K99/R00, KL1, KL2, R25, R36, T15, T32, T34, T35, T36, T37, T90/R90, TL1, TU2, and U2R. This policy also applies to any other NIH-funded programs supporting research training, career development, or research education that require instruction in responsible conduct of research as stated in the relevant funding opportunity announcements. The requirements are described here on the NIH's website.

Note: Instruction should include face-to-face discussions by course participants and faculty; i.e., on-line instruction may be a component of instruction in responsible conduct of research but is not sufficient to meet the NIH requirement for such instruction, except in special or unusual circumstances. For more information, please access the faculty guide links below:

NIH Faculty Guide for Responsible Conduct of Research (MS Word)

Conflict of Interest for Responsible Conduct of Research (PPT)

Conflict of Interest Quiz

Training for Public Health Service Funding

  1. Go to the Collaborative Institutional Training Initiative (CITI) login page.
  2. Register as a new user
    Note: if you already have a log in and password, skip to # 6 (below)
  3. Be sure to locate University of Nevada, Reno in the drop down options
  4. When you get to the options for which training you would like to take, scroll down to Question 1: Human Subjects Research and choose "N/A" - scroll down to Question 4: Conflict of Interest (COI) and click "Yes"
    Note: You do not have to click on any of the modules under Question 3: Responsible Conduct in Research (RCR), unless you would like to (or have another obligation such as National Science Foundation (NSF) funding that require it)
    Screen shot showing the questions section
  5. Scroll down and click on continue. You will be taken back to your home page where you will see "Not Started - Enter."
    Note: You may start and stop the modules as many times as needed, log out and back in as time permits, it will pick up where you left off.
  6. Log in using your registered username and password. If you have forgotten your username and/or password, send an e-mail to and she will e-mail the information back to you.
  7. From your home page, click on: "Add a course or update your learner groups"
    Screen show showing which courses you have selected
  8. Scroll down to Question 4: Conflict of Interest (COI) and choose "Yes"
  9. Return to #4 (above) and complete through #5 (above)