About Conflicts of Interest in Research
This page covers the Conflict of Interest (COI) process and procedure for submission and review of COI disclosures. Researchers must submit financial disclosure forms at the time of initial proposal submission for research funding, when additional funding or supplemental funding is received, when a no-cost extension is requested, when research gift funding is received, when a personnel change takes place, when any new significant financial interest is acquired, and when an application for a protocol is submitted for a human subjects study. Conflict of Interest reporting is separate, and in addition to, Conflict of Commitment reporting, which is governed by APM - 025 and is managed by Academic Personnel.
“Funding” includes money and/or materials. “Conflicts” include intellectual property (“IP”), income, investments, service on a Scientific Advisory Board (or its equivalent), member of Board of Directors, employee of a company or entity, ownership of a company, and so forth.
Conflicts must be reviewed and approved before funding can be accepted and the research can begin.
Proposals for Federal Research Funding submitted through the Office of Research:
Submit your disclosure at least annually and within 30 days of new financial interests electronically via ORCOI. First time users must have their access initiated by COI staff. To gain access to the system, send a request to email@example.com.
The instructions for submission of paperwork for research gifts are located on the COI web page in the For Researchers page under Research Gifts.
Review by COI Staff:
COI staff review all disclosures submitted through ORCOI for completeness. If the disclosures are negative, then the COI staff will inform Contracts and Grants via ORBiT. "Positive" disclosures may result in a request for additional information.
Review by COIC:
The COIC reviews positive disclosures at its monthly meeting. When the COIC deems potential conflicts to be adequately managed or acceptable they authorize the COI staff to release the funding in ORBiT or to notify gift administration about the status of the conflict review.