About Conflict of Interest in Research
This page covers the COI process and procedure for submission and review of COI paperwork for research. Please refer to the COI disclosure forms and the remainder of this website for more specific information about the details that need to be disclosed and reviewed by the COIAC.
Faculty members must submit financial disclosure forms at the time of proposal submission for research funding, when research gift funding is received, and when an application for protocol is submitted for a clinical study.
“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 cleared before funding can be accepted and the research can begin. Failing to submit appropriate forms or submitting incomplete or inaccurately completed forms may delay the final disposition. Submitting incomplete information or falsifying information may lead to professional, civil, and criminal action against the faculty member and UC.
Proposals for Research Funding submitted through Contracts and Grants, Industry Contracts Division, or Business Research Units:
Submit the required COI disclosure form(s) with the proposal paperwork to the appropriate division (listed above) at the time of proposal submission. Refer to these COI web pages for the correct forms: (1) Laws and Regulations, (2) Specific Situations, and (3) Disclosure Chart. (The OSR divisions listed above will forward the COI disclosure forms to COI staff.)
Proposals for protocol application for clinical study submitted through CHR:
Submit the CHR Financial Supplement with the CHR Application if any Investigator (a defined term on the CHR Financial Supplement) has a potential conflict of interest to disclose. CHR will give a copy of the CHR Financial Supplement and the application to the COI staff.
Research Gifts:
The instructions for submission of paperwork for research gifts are located on the COI web page about Research Gifts, which web page links to the Gift Administration website for detailed instructions.
Review by COI Staff:
COI staff reviews all incoming disclosure forms for completeness, accuracy, and presence of all required disclosure forms and attachments. If the form is incomplete or it is the wrong form, the COI staff will ask for a new form. If the form is complete and all boxes are checked “no,” then the COI staff will release in RAS. If any box is checked “yes” or is not checked, the disclosure form is deemed to be a “positive” disclosure. The COI staff will ask for more information and/or a new form.
Review by COIAC:
The COIAC reviews simple conflicts or previously reviewed conflicts on an expedited basis, and authorizes the COI staff to release the funding in RAS or to notify CHR about the status of the conflict review. For more complex conflicts, the COIAC reviews these at its monthly meeting. See the COIAC Meeting Schedule under the COIAC web page.
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