We provide Clinical Decision Support for

Accurate decision support empowers the public to better understand medical conditions they are concerned about and make informed medical decisions about seeking care.

Providing accurate information to patients is an evidence-based approach that increases patient engagement in their care and improves patient satisfaction.

Giving care providers accurate tools to understand a patient’s condition improves care and decreases healthcare costs.

Get to know our work

Why we are here

FTHR Group was founded in 2024 as a logical extension of the work we had been doing to lead CDC’s COVID-19 Self Checker forward triage tool and the agency’s telehealth unit during the pandemic. The Self Checker had more than 21 million conversations with users during its two years of operation. Its companion program, CDC’s vSafe post-vaccine checker, has had more than 200 million interactions, all with around four staff. These programs remain some of the most highly visited websites in the CDC’s history and some of the most widely used forward triage/symptom monitoring applications in the U.S. during the pandemic. These applications and similar work signaled a new era of patient- and public-facing clinical decision support (CDS) applications that can now build upon a substantial evidence base of using clinician-focused CDS in healthcare systems.

Where we work

Enhanced public awareness of CDS applications and success in deploying them will continue to catalyze the use of public- and patient-facing CDS applications. These will help users identify (and potentially address) medical issues before or while they seek further care, direct them to the most appropriate care, and reduce unnecessary costs in the fractured and high-friction U.S. healthcare system. In addition, advances in technology will allow first-entry healthcare providers (e.g., emergency service personnel and nursing staff) to use CDS to better assess patients and implement evidence-based approaches earlier in the healthcare process. These interventions will further improve health outcomes, quality of patient care, and overall patient satisfaction. The low use of physician and mid-level provider CDS, as well as variable accuracy of symptom checkers that attempt to diagnose a broad range of conditions, provides opportunities for FTHR Group to develop accurate, condition-specific applications with evidence-based interventions or guidance for the public, patients, healthcare systems, and healthcare payers.

Measuring success

FTHR Group will build on its experience to develop, implement, evaluate, and manage public-, patient-, and first-entry healthcare provider-driven CDS. Our success will be measured by users of institutionally-associated or individual CDS applications that provide accurate information to empower them to make informed healthcare decisions. These tools will increase user satisfaction and reduce costs associated with unnecessary care, improving the health of these populations and saving the precious time of both patients and providers.

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Financial Conflict of Interest (FCOI) Policy

Effective: June 1, 2026

1) Introduction

The purpose of this policy is to ensure that research funded by the National Institutes of Health (NIH) is designed, conducted, and reported objectively and without bias resulting from Investigator financial conflicts of interest (FCOI). The 2011 revised regulations are 42 CFR Part 50 Subpart F, “Promoting Objectivity in Research” and 45 CFR Part 94, “Responsible Prospective Contractors”, which set requirements for promoting objectivity in Public Health Service (PHS)–funded research for grants, cooperative agreement, and research contracts, respectively. The regulations do not apply to SBIR or STTR Phase I applications or awards. This policy implements the regulatory requirements for PHS/NIH grants and cooperative agreements.Forward Triage Healthcare Resources Group, LLC (“FTHR Group”, “The Institution”) adopts this policy for all Investigators (as defined below) engaged in PHS/NIH-funded research. It establishes processes to identify, disclose, and manage Investigator financial conflicts of interest to protect research integrity, ensure the safety of human and animal subjects, and maintain public trust in PHS/NIH-supported research.

2) Applicability

This policy implements the regulatory requirements provided in 42 CFR Part 50 Subpart F for grants and cooperative agreements issued by the NIH. This policy applies to individuals who meet the regulatory definition of “Investigator” (as defined below) who are planning to participate in or who participate in PHS/NIH-funded research.

3) Definitions

For the purpose of these policies and procedures, the following definitions apply:Financial Conflict Of Interest (FCOI)
A significant financial interest that is related to the PHS/NIH- funded research (i.e., the SFI could be affected by the research or the SFI is in an entity whose financial interest could be affected by the research) and could directly and significantly affect the design, conduct, or reporting of PHS-funded research.Financial Interest
Anything of monetary value, whether or not its value is readily ascertainable.Institutional Responsibilities
The professional responsibilities of an Investigator on behalf of FTHR Group, which may include activities such as research, research consultation and collaboration, product development, product testing and validation, development of datasets, models, or systems, publication and communication of research results, and other professional services performed on behalf of FTHR Group.Designated Official (DO)
The individual appointed by FTHR Group to solicit and review disclosures of significant financial interests, determine FCOIs in accordance with 42 CFR 50.604(f) and this policy, and develop management plans for identified FCOI.Institution
Any public or private organization, domestic or foreign (excluding a federal agency) that is applying for or receives PHS/NIH research funding.Investigator
The Project Director (PD) or Principal Investigator (PI), and any other person, regardless of title or position, who is responsible for the design, conduct, or reporting of research funded by PHS/NIH or proposed for such funding, which may include, for example, collaborators or consultants. The Institution determines who is responsible for the design, conduct, or reporting of PHS/NIH-funded research. The Institution will consider the individual’s role, rather than the title (e.g., senior/key personnel, faculty, MD, PHD, etc.), of those individuals involved in the research and the degree of independence in carrying out the work when determining who is responsible for the design, conduct, or reporting of the PHS/NIH-funded research. Institutional responsibilities mean an Investigator's professional responsibilities on behalf of the Institution, and as defined by the Institution in its policy on financial conflicts of interest, which may include 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.Manage
Means taking action to address a financial conflict of interest, which can include reducing or eliminating the financial conflict of interest, to ensure, to the extent possible, that the design, conduct, and reporting of research will be free from bias.Research
Means a systematic investigation, study, or experiment designed to develop or contribute to generalizable knowledge relating broadly to public health, including behavioral and social sciences research. The term encompasses basic and applied research (e.g., a published article, book, or book chapter) and product development (e.g., a diagnostic test or drug). As used in the regulation, the term includes any such activity for which research funding is available from a PHS Awarding Component through a grant or cooperative agreement; whether authorized under the PHS Act or other statutory authority, such as a research grant, career development award, center grant, individual fellowship award, infrastructure award, institutional training grant, program project or research resources award.PHS-Funded Research
Any activity supported by a Public Health Service (PHS) Awarding Component through a grant, cooperative agreement, or contract; whether funded under the PHS Act or other statutory authority.PHS
The Public Health Service of the U.S. Department of Health and Human Services, and any components of the PHS to which the authority involved may be delegated, including the National Institutes of Health (NIH).NIH
The biomedical research agency within the Public Health Service (PHS) that funds and conducts research to improve health and advance scientific knowledge.Senior/Key Personnel
The PD/PI and any other individual identified as senior/key personnel by the Institution in a grant application, progress report, or other submission to PHS/NIH. For this policy, the term applies specifically to the public accessibility requirement, which mandates disclosure only of financial conflicts of interest held by these senior/key personnel, as described in Section 9.Significant Financial Interest (SFI)

The disclosure requirement does not apply to travel that is reimbursed or sponsored by the following:

Foreign Financial Interests
Investigators must disclose all financial interests originating outside the United States, including income from seminars, lectures, teaching engagements, service on advisory committees or review panels, and reimbursed or sponsored travel received from any foreign entity. This includes foreign institutions of higher education and foreign governments (including local or provincial governments). Disclosure is required when the aggregated amount of such income meets the threshold for disclosure (e.g., income in excess of $5,000).

4) Significant Financial Interst (SFI) Disclosure Requirements

Investigators will disclose their SFIs that are related to their “institutional responsibilities” as defined in the policy.The disclosure will not be limited to an Investigator’s research responsibilities or their funded research as this is too narrow in scope and not consistent with the 2011 regulation.The Investigator SFI Disclosures will be retained by the Institution as part of the record maintenance requirements.Investigators are required to disclose SFIs at the following times:

5) Review of SFI Disclosures

The FTHR Group Chief Executive Officer or their designee serves as the Designated Official (DO) responsible for reviewing all SFI disclosures. In cases where the DO has a disclosed SFI related to the research under review, or where additional independence is warranted, the DO will recuse themselves from the review and determination. In such cases, an alternate qualified designee or external advisor may be appointed to perform the review. The use of such alternative review arrangements will be documented.Each SFI will be evaluated in relation to every PHS/NIH research application or award on which the Investigator is responsible for the design, conduct, or reporting of research, to determine whether the SFI is related to the funded research and, if so, whether it constitutes a Financial Conflict of Interest (FCOI).The SFI disclosures will be reviewed as described below:

An FCOI report will be submitted to NIH within 60 days of identifying the FCOI.

6) Relatedness of SFIs to PHS/NIH-Funded Research and FCOI

The DO is responsible for assessing the relatedness of SFIs to NIH-funded research and determining when they constitute a FCOI.Relatedness Test: The DO determines whether an Investigator’s SFI is related to research under an NIH award. An SFI is considered “related” when the DO reasonably determines that:

Investigator involvement: The DO may consult with the Investigator when assessing whether an SFI is related to the research.Designated Official FCOI Determination: An FCOI exists when the DO reasonably determines that the SFI could directly and significantly affect the design, conduct, or reporting of the PHS/NIH- funded research (“significantly” meaning that the financial interest would have a material effect on the research).

7) Management of SFIs that Pose an FCOI

When an FCOI is identified, the DO will determine and implement management strategies to ensure the research is conducted objectively. Examples of management conditions include, but are not limited to:

The DO will communicate the determination and the management plan in writing to the Investigator and the appropriate supervisor.No expenditures on an NIH award may occur until the Investigator has met all disclosure requirements and agreed in writing to comply with the management plan. The DO will submit an FCOI report to NIH via the eRA Commons FCOI Module.In addition to FCOI, FTHR Group recognizes that certain financial interests at the institutional level, including company equity, intellectual property interests, or financial relationships of senior leadership, may present potential conflicts related to PHS/NIH-funded research. Such interests will be evaluated and managed as appropriate to ensure the objectivity of the research.

8) Monitoring Investigator Compliance

The FTHR Group DO will monitor Investigator compliance with the management plan for the duration of the NIH award.FCOIs are made in publications, presentations, and other communications. Investigators must also disclose the FCOI in writing to study personnel and provide a copy of this disclosure to the DO for recordkeeping.

9) Public Accessibility of the FCOI Policy and FCOIs Held by Senior/Key Personnel

FCOI Policy: A copy of this FCOI policy is available on FTHR Group’s public website as required by Section 4.1.10 Financial Conflict of Interest of the NIH Grants Policy Statement.Identified FCOIs held by Senior/Key Personnel: Before any funds are spent under an NIH award FTHR Group will ensure public accessibility by providing a written response within five business days to requests for information about any SFI that meets all three of the following criteria:

When applicable, FTHR Group will make available at least the following information:

The information posted on FTHR Group’s website will be updated at least annually and within 60 days of:

Information on SFIs subject to the public accessibility requirement will remain available for at least three years from the most recent update. The written response will note that the information provided is current as of the date of the correspondence and is subject to updates on at least an annual basis and within 60 days of the institution’s identification of a new FCOI, which should be requested subsequently by the requestor.When the subrecipient Investigator is required to comply with the subrecipient’s FCOI policy, the subrecipient Institution will also make such information publicly accessible.

10) Reporting Identified Financial Conflicts of Interest

Prior to spending any funds under an NIH-funded award, FTHR Group will submit an identified FCOI report to NIH, in accordance with the FCOI regulations, for any Investigator’s SFI determined to be a FCOI. FTHR Group will also ensure that the Investigator has agreed to and begun implementing the associated management plan.FTHR Group will designate an institutional official to act as the FCOI Signing Official (FCOI SO) in the eRA Commons FCOI Module. The FCOI SO is authorized to submit FCOI reports to NIH. FCOI reports are submitted only when an award is active, and an FCOI has been identified (i.e., no award means no FCOI report, and no FCOI means no FCOI report).The NIH eRA Commons FCOI Module User Guide, available at the following location, provides instructions for preparing and submitting FCOI reports. https://www.era.nih.gov/files/fcoiuserguide.pdfInitial (Original) FCOI Reports: The report must include all information required under 42 CFR 50.605(b)(3) or as outlined in the NIH FAQH.5.

Annual FCOI Reports: For the duration of an award, including any extensions with or without funds, the Institution must submit an annual FCOI report to NIH. This report will indicate whether each previously reported FCOI is still being managed or no longer exists and describe any changes to the management plan, if applicable.

Revision (or Mitigation) FCOI Reports: After completing a retrospective review, the Institution will submit a Revision report to NIH if new information about the FCOI is discovered, or a Mitigation report if the review finds that bias has occurred.Types of FCOI Reports, content, and timeline requirements:

NIH FCOI Module guide: era.nih.gov/files/fcoiuserguide.pdf

11) Training Requirements for Investigators

Each Investigator will be informed of FTHR Group’s FCOI Policy and trained on their responsibility to disclose foreign and domestic SFIs under this policy and the FCOI regulation at 42 CFR Part 50 Subpart F. Training must be completed before an Investigator engages in PHS/NIH-funded research, at least once every four years, and promptly (as described below) when any of the following occur:

To meet the NIH training requirement, FTHR Group requires Investigators to complete the NIH FCOI Training Module from the following location: https://grants.nih.gov/policy-and-compliance/policy-topics/fcoi/fcoi-training. FTHR Group also requires Investigators to review the NIH Virtual Seminar presentation on FCOI compliance from the following location: https://www.youtube.com/watch?v=D292YZ6BX24. Investigators need to send the DO the date of completion of each of these through email to ensure they can be audited.

12) Noncompliance With FCOI Policy and Corrective Actions

If FTHR Group identifies an SFI that was not disclosed, reviewed, or managed in a timely manner, the DO will, within 60 days: review the SFI; determine whether it is related to NIH-funded research; determine whether it constitutes an FCOI; and, if so, implement an interim management plan describing actions that have been and will be taken to manage the FCOI going forward. FTHR Group will also submit an FCOI report to NIH via the eRA Commons FCOI Module.In cases of noncompliance, including:

FTHR Group will, within 120 days of identifying noncompliance:

If bias is found, FTHR Group will promptly notify NIH and submit a mitigation report as required by 42 CFR 50.605(a)(3)(iii) or as described in NIH’s FAQ I.3 to NIH via the FCOI Module.The report will include:

FTHR Group will thereafter submit FCOI reports annually to NIH as required by the regulations and the terms and conditions of the award. Depending on the circumstances, FTHR Group may implement additional interim measures regarding the Investigator’s participation in the research until the retrospective review is complete.If bias is not found following completion of the retrospective review, no further action will be taken unless new information is discovered that needs to be reported to the NIH. If applicable, the Institution will update an existing FCOI report to specify the actions that have been, and will be, taken to manage the FCOI going forward or update a previously submitted report information (e.g., increase in value of the SFI or add any newly identified SFIs) following the completion of the retrospective review.If the failure of an Investigator to comply with an Institution's FCOI or a FCOI management plan appears to have biased the design, conduct, or reporting of the PHS/NIH-funded research, the Institution shall promptly notify the PHS/NIH Awarding Component of the corrective action taken or to be taken. The PHS/NIH Awarding Component will consider the situation and, as necessary, take appropriate action, or refer the matter to the Institution for further action, which may include directions to the Institution on how to maintain appropriate objectivity in the PHS/NIH-funded research project. PHS may, for example, require Institutions employing such an Investigator to enforce any applicable corrective actions prior to a PHS/NIH award or when the transfer of a PHS/NIH grant(s) involves such an Investigator.

13) Clinical Research Requirements

If HHS determines that a PHS-funded clinical research project evaluating the safety or effectiveness of a drug, medical device, or treatment was designed, conducted, or reported by an Investigator with an unmanaged or unreported FCOI, FTHR Group will require the Investigator to disclose the conflict in every public presentation of the research results and to request an addendum to previously published presentations.

14) Subrecipient Requirements

A subrecipient relationship exists when federal funds flow from or through FTHR Group to another individual or entity that will carry out a substantive portion of a PHS/NIH-funded research project and is accountable to FTHR Group for programmatic outcomes and compliance.Subrecipients (e.g. collaborators, consortium members, consultants, contractors, subcontractors, and sub-awardees) are subject to FTHR Group’s terms and conditions. FTHR Group will take reasonable steps to ensure that all subrecipient Investigators comply with the federal FCOI regulations at 42 CFR Part 50 Subpart F. FTHR Group will include in each written agreement with a subrecipient terms specifying whether FTHR Group’s FCOI Policy or the subrecipient’s own FCOI policy will apply to subrecipient Investigators (see NIH Grants Policy Statement Section 15.2.1 on Written Agreements).

1.    If the subrecipient’s FCOI policy applies:The subrecipient institution must certify in the agreement that its policy complies with federal FCOI regulations. The agreement will specify the timeframe for the subrecipient to report identified FCOIs to FTHR Group in time for FTHR Group to meet NIH reporting deadlines (i.e., before funds are spent and within 60 days of the subrecipient identifying an FCOI). Typically, this means requiring subrecipients to report FCOIs to FTHR Group within 50–55 days of identification. FTHR Group’s DO will then submit the subrecipient FCOI report to NIH through the eRA Commons FCOI Module.2.     If the subrecipient cannot certify compliance:The agreement will specify that FTHR Group’s FCOI Policy applies. In this case, subrecipient Investigators must disclose their SFIs to FTHR Group. The SFI disclosure must include SFIs that are directly related to the subrecipient’s work for FTHR Group. The agreement will allow sufficient time for FTHR Group to review, manage, and report any resulting FCOIs. When an FCOI is identified, FTHR Group will implement a management plan, monitor compliance by the subrecipient Investigator, and submit the required FCOI report to NIH via the eRA Commons FCOI Module.

15) Maintenance of Records

FTHR Group will maintain records of all Investigator financial interest disclosures, FTHR Group’s review and response to those disclosures (whether or not they resulted in a determination of an FCOI), and any actions taken under this policy or through retrospective review. These records will be retained for at least three years from the date of submission of the final expenditures report, or for longer periods as specified in 2 CFR 200.334 for specific situations. FTHR Group will retain these records for each competitive segment as required by regulation. Copies of management plans will be retained as part of the record maintenance requirements.

16) Enforcement Actions for Investigator Noncompliance

Compliance with this policy is a condition of employment and/or participation for all applicable Investigators. Failure to comply with this policy, including failure to disclose Significant Financial Interests, failure to comply with a Conflict Management Plan, or failure to complete required training, may result in appropriate corrective or disciplinary actions.Such actions may include, but are not limited to, formal notification or disciplinary measures, restrictions on participation in research activities or use of research funds, suspension or termination of employment or contractual relationship, and/or disqualification from participation in Government Award–funded research, as appropriate.In addition, FTHR Group will take all actions required under applicable federal regulations and sponsor requirements, including conducting retrospective review, implementing mitigation measures where necessary, and notifying the sponsor when required.

17) Useful FCOI and NIH Resources

NIH e-mail address for FCOI-related inquiries: fcoicompliance[at]mail.nih.govFCOI Regulation 42 CFR Part 50 Subpart F - Promoting Objectivity in Research: https://www.ecfr.gov/current/title-42/chapter-I/subchapter-D/part-50/subpart-FFinancial Conflict of Interest: https://grants.nih.gov/policy-and-compliance/policy-topics/fcoiFCOI Training: https://grants.nih.gov/policy-and-compliance/policy-topics/fcoi/fcoi-trainingNIH “Welcome Wagon” Letter: Information for New Recipient Organizations: https://grants.nih.gov/policy-and-compliance/welcome-wagon

18) Point of Contact

If you have a question related to the FCOI Policy of FTHR Group, or would like to disclose a financial interest, contact us using the information below:

Contact:
Antonio Neri, MD, MPH, FACPM, Capt. USPHS (Ret.)
Chief Executive Officer
FTHR Group, LLC.
Email Antonio