Process for Disclosure and Role of COI Committee

Conflict of interest annual disclosures and Project related COI disclosures are now completed via the Cayuse Outside Interests online module.

Answers to some frequently asked questions:

To whom does this apply?

Conflicts of Interest and Commitment applies to:

• Faculty (9 month, 12 month, and part-time).
• EHRA staff members
• Research personnel involved in the design, conduct, or reporting of a funded research project, contract, sub-contract, or other agreement.
• Individuals responsible for the design, conduct, or reporting of a Public Health Service (PHS) funded research project are also required to disclose sponsored travel and paid authorships.

Disclosures must include the Significant Financial Interests of family members (i.e., spouse and dependent children).

When should I submit the COI disclosure for my research/project proposal?

Conflict of Interest Disclosures should be completed prior to the submission of any funding proposal for any COI that is related to the proposed project. The Office of Research Integrity will now be an integral part of the proposal submission process, verifying that the COI disclosures have been completed for any individual involved in the design, conduct, or reporting of research as required by federal PHS policy.  Proposals will not be submitted without this being completed, so be sure to log-in to Cayuse and complete this crucial step.

Subcontracts and Non-University Employees

Individuals responsible for the design, conduct, or reporting of a PHS funded research project may include non-university personnel, such as subcontractor employees, collaborators, or consultants. If the subrecipients’ home institution does not have a PHS compliant COI policy, then that subrecipient must agree to be subject to the UNC Greensboro COI policy.

Note: Phase I Small Business Innovation Research (SBIR) or Phase I Small Business Technology Transfer Research (STTR) grants are excluded from the PHS COI regulations. However, Phases II & III are not excluded from the PHS COI regulations.

What is the deadline for completing the Annual Disclosure process?

The deadline for completing Annual Disclosures is September 30^th. This revised time frame reduces the burden of end-of-the-year administrative tasks, and better aligns with the intent of the disclosure process to be forward thinking (e.g., you are asked to disclose current activities and those anticipated over the next year). Reminders will be sent out to the Campus Community at the start of the Fall semester.

For situations that may generate a conflict that are not research related, those should be disclosed via the Annual COI Disclosure form when the situations arise, and updated during the Annual Disclosure process thereafter.   For example, situations involving faculty who own or have an interest in an outside businesses, or engage in a consulting relationship that could potentially overlap with their UNCG teaching or administrative responsibilities.

What happens once I complete the disclosure process?

You should receive an email indicating that your disclosure has been received. The next steps depend on the content of your disclosure:

• If you answered “No” to all questions, then your annual disclosure process is complete.
• If you answered “Yes” to any questions, you will receive a follow-up email indicating whether additional steps (e.g., review by the COI Committee, creation of a management plan) are needed.
• If you have a potential conflict that needs to be addressed immediately, please contact UNCG’s Office of Research Integrity at ori@uncg.edu.

How do I determine the status of my disclosure once I’ve submitted it?

You can check the status of your disclosure and review prior disclosures at any time by logging into Cayuse, clicking on “My Profile” in the drop down menu under your name on the right hand side of the screen, then clicking on “COI Disclosures” at the bottom of the list on the left. You’ll see a list of all disclosures that you’ve made, their status and submission dates for all Annual and Project-based disclosures.

Now that we are using the Cayuse system, what is the process for reviewing disclosures?

All disclosures will receive an initial administrative review by COI Staff in the Office of Research Integrity. Department Heads/Chairs and other supervisors will continue to play a key role in the determination process when a potential conflict of interest exists; they also will be given a summary report that indicates the Annual Disclosure status for individuals within their units. The Conflict of Interest Official will serve in a case management role, shepherding situations where a potential conflict of interest exists through the review process by coordinating communication and information, providing guidance on policy, and referring cases to the COI Committee when appropriate. For those with known conflicts and/or existing management plans, this also will allow for greater streamlining of the review process.

What is the COI Committee and what is their purview?

The main function of the Conflict of Interest committee is to review COI cases that relate to research and other forms of scholarship. The COI Committee primarily reviews COI cases related to externally funded projects. UNCG is required by federal regulations to evaluate, manage, and report conflicts of interest in instances where federal funding is involved. The COI Committee also may review research-related COI when external funding is not involved. This is most likely to happen when human subjects research is involved. This committee serves in an advisory role to the Provost’s Office and the Office of Research and Economic Development.

Members of the committee are selected to be representative of the disciplines, but also knowledgeable of the topic at hand (including the COI regulations of not only the UNC system and UNCG, but also multiple federal agencies). Staff in the Office of General Counsel, Office of Sponsored Programs, the Office of Research Integrity, Innovation Partnership Services, and other offices provide additional expertise and consultation.

Questions should be directed to Dr. Lisa Goble, lagoble@uncg.edu or 336-256-1173.