Compliance Monitoring

When the Individual Conflict of Interest Committee determines that a conflict of interest exists and requires a management plan, those managed individuals may be required to submit reports annually to certify their compliance with the approved management plan. These compliance reports are submitted in the ERICA system.

Self-Reporting of Potential Conflicts of Interest

COI review generates automatically for research that goes through the University's Institutional Review Board (IRB) and Office of Sponsored Projects (OSP). However, individuals should submit a Conflict Reporting Form to initiate a review of:

1. Unsponsored or internally funded Research that is not administered by the IRB or OSP
2. Scholarly or Educational Activity
3. Transactions (ex. purchases, contracts, subawards, license negotiations, lease agreements, etc.)
   
   

Non-compliance: Retrospective Reviews and Mitigation Reports

When 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) or other federal sponsors with substantially similar requirements as the PHS. If bias is found, the University must notify the federal sponsor promptly and submit a mitigation report.

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.

Open Payments Compliance Review

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.