When the Individual Conflict of Interest Committee determines that a conflict of interest exists and requires a management plan, the plan will require investigators and employees to submit reports annually to certify their compliance with the approved management plan. Annual Compliance Reports can be submitted in ERICA.
Self-Reporting of Potential Conflicts of Interest
Sponsored research administered by the Office of Sponsored Projects (OSP) and Human Subjects Research administered by the Institutional Review Board (IRB) include built in mechanisms for conflict of interest review by the COI Office. These activities do not need to be self-reported. Other activities subject to oversight by the Individual Financial Conflict of Interest Policy (1-006) may not have mechanisms to create automated reviews. Therefore, it is the responsibility of potentially conflicted individuals to submit a Conflict Reporting Form when their University activities are reasonably related to their Financial Relationships. These activities include, but are not limited to:
- Unsponsored, or internally funded, Research that is not administered by OSP or IRB,
- Scholarly or Educational Activity,
- Business Transactions including, but not limited to, purchases, contracts, subawards, license negotiations, lease agreements, etc.
Non-compliance: Retrospective Reviews and Mitigation Reports
Whenever a conflict of interest is not reported or managed in a timely manner, the University may complete a “retrospective review” of the investigator’s activities and the research project to determine whether any research conducted during the time period of the noncompliance was biased in the design, conduct, or reporting of such research. Retrospective reviews are required if the research is sponsored by the Public Health Service (PHS). If bias is found, the University must notify PHS promptly and submit a mitigation report to the NIH.
Reports of potential non-compliance or policy violations can be made to the COI Office directly, on-line using EthicsPoint, or through the Ethics and Compliance Hotline (888) 206-6025.
Peer Monitor Reporting
Some management plans require individuals with conflicts of interest to name a non-conflicted peer or supervisor to monitor certain activities related to the conflict of interest. This link provides additional guidance for individuals serving as Peer Monitors.
Access and submit COI forms related to specific projects
Business Relationship Reporting
Conflict Reporting Form
Self-report a COI related to job responsibilities
Anonymously report a non-compliance or a policy violation
Peer Monitor Reporting
Review a list of questions to consider in your report