- Whom do I contact?
- How do I know if I need to submit a financial disclosure form? When do I submit the form?
- How do I get started?
- What are the training obligations? Are educational resources available?
- How does the University determine if there is a conflict of interest related to research?
- What should I expect if it is determined that I have a conflict of interest? How do I get a management plan?
- Will I be monitored after I receive a management plan?
- What are my continuing obligations concerning conflict of interest?
- Relevant policies, procedures, and links.
The Conflict of Interest in Research Office is part of the Office of the Vice President for Research.
2. How do I know if I need to submit a financial interest disclosure form? When do I submit the form?
Anyone involved in externally-sponsored non-human subjects research or human subjects research, whether externally sponsored or not, must annually file a financial interest disclosure form. “Involved in research” means that you are named as key personnel on a proposal routing form or an IRB application.
In order to be named on a routing form or IRB application, you must have a disclosure form on file, even if you have no financial interests in non-University entities.
There is a disclosure period during the first quarter of every calendar year, and researchers are required to keep the disclosure form up-to-date throughout the year. If you are going to arrive at the University after the disclosure period, you can submit your disclosure form as soon as you have a Hawk-ID and password.
Conflict of interest training is required for all researchers prior to initiating research and then every four years. The training module is embedded in the financial interest disclosure form, so you can complete the training and disclosure requirements simultaneously by logging in to the eCOI system with your HawkID and password.
When you submit a proposal to the Division of Sponsored Programs, you will be asked whether any of your previously-disclosed financial interests are related to the project. Then the Conflict of Interest in Research Office will review your research proposal and financial interest disclosure form to determine whether your financial interest(s):
- Meet thresholds specified by federal regulation and University policy
- Could directly and significantly affect the design, conduct, or reporting of the research
If your financial interests meet these requirements, a conflict of interest (or the appearance of a conflict) may exist.
6. What should I expect if it is determined that I have a conflict of interest? How do I get a management plan?
The Conflict of Interest in Research Committee, with faculty representation from a broad range of research disciplines, will review the materials related to your financial interest(s) and the proposed research. The Committee will develop a recommended management plan and send it to the Vice President for Research. Then a written management plan will be sent to you for your review and signature. You may contact the Conflict of Interest in Research Office if you want to discuss your management plan.
The Conflict of Interest in Research Office may monitor whether you are following the terms of your management plan. All issued management plans are subject to monitoring. Therefore, it is important that you be able to document your compliance. For example, when you publish or present study results, retain any notices about your conflict of interest sent to journals, conference organizers, etc.
You are responsible for updating your disclosure form annually during the period of the research, and within 30 days of identifying or acquiring a new financial interest.