Conflict of Interest FAQ's

How do I file my report?
Why is this reporting necessary?
What is a disclosure and what is a certification?
How does the eCompliance system work?
What do I need to complete the form?
How often do I have to submit a certification?
What happens to the information I submit?
Who is required to file Conflict of Interest (COI) reports?
What is a Conflict of Interest?
What is a Conflict of Time Commitment?
How often is filing required?
What's new in the COI Reporting process for most faculty and unclassified staff members?
What's new in the COI Reporting process for PHS-Sponsored researchers?
What are the PHS–compliant agencies?
What forms are filed?
What does the supervisor's signature indicate?
What are the consequences of failing to comply?
I've reported my consulting activities on my Conflict of Interest report. Does this satisfy the reporting and approval requirements of the KU Consulting Policy?
My grant application form contains a conflict of interest certification. If I've certified that I have no conflict of interest on a grant proposal, do I still need to submit a Conflict of Interest report?
What is the difference between the State of Kansas Statement of Substantial Interests and Board of Regents Conflict of Interest Reporting?
 

How do I file my report?
All certifications go through the eCompliance system. A KU Online ID is required to log into the system.

More information on the COI Reporting System can be found in the Guides on Policies and Procedures page.

Why is this reporting necessary?
As required by federal, Regents and University of Kansas policy, all faculty and unclassified staff and any other members of the University community who are responsible for the design, conduct, or reporting of research or educational activities are required to disclose relevant financial interests. Additionally, Regents and University policies require all faculty and unclassified staff to disclose external professional activities that entail time commitments, whether paid or unpaid.

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What is a Disclosure? What is a Certification?
A disclosure is the act of making new or unknown information known. In this case it is a statement of your or your immediate family’s relationship relating to financial interests or time commitments, as qualified by federal, Regents and University policy.

A certification is a statement of assurance. In this case a statement assuring that you listed all relevant disclosures and accurately reflected your current relationship with those disclosed entities.

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How does the eCompliance reporting system work?
eCompliance is a web-based interface designed to collect and review certifications submitted by eligible KU faculty, staff and investigators. The online forms provide the criteria for reporting information about entities with which you have professional time commitments and/or significant financial interests (SFI) that meet thresholds for disclosure. You will list each entity that meets disclosure criteria along with descriptions of your current relationship. For example, you might have a time commitment and receive compensation for your work as a consultant for a non-profit organization; you may have no time commitment but your spouse holds equity in a colleague's startup company, or you could have no financial interest but have a time commitment as an officer of a professional organization. The eCompliance system saves your list of disclosures as a continuing part of your reporting record that you will update annually and when circumstances change, such as when you acquire a new significant financial interest or your current relationships change.

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What do I need to complete the form?
After making disclosure(s) and/or updates, the online reporting system will ask that you certify your disclosures are accurate and complete. Once you make this certification, your information will route electronically for review.

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How often do I have to submit a certification?
Faculty and unclassified staff must submit a certification annually and on an ad hoc basis as new significant financial interest (SFI) arise. In addition, all investigators participating on proposed or awarded PHS-sponsored projects must complete a proposal/award specific certification providing their disclosed financial interests at the time of proposal submission and progress reports. Periodic conflict of interest training is also required of these individuals.

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What happens to the information I submit?
The University is responsible for reviewing all disclosures and determining whether an outside interest constitutes a conflict of interest with University responsibilities. Your immediate supervisor will be asked to review your certification if you have made any disclosures. After Supervisor Review, the certification is routed for administrative review and, if necessary, to the Conflict of Interest Committee.

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Who is required to file Conflict of Interest (COI) reports?
Kansas Board of Regents and the KU-Lawrence policies require conflict of interest reporting by:

  • all faculty and unclassified academic and professional staff members
  • any other investigator on a sponsored research project who is responsible for the design, conduct, or reporting of research, which may include certain sub-recipients from PHS compliant agencies

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What is a Conflict of Interest?
"Conflict of interest" refers to reported financial, managerial or time commitment disclosures that may compromise, or have the appearance of compromising, scientific judgment, integrity of research data, fulfillment of professional duties, or the safety and welfare of research volunteers. Disclosed activities define conflicts of interests as they relate to KU employment and research commitments.  Individual character or actions do not substantiate a conflict of interest.

Conflicts can be individual or institutional in nature. Individual conflict of interest may be associated with financial incentives in research, business ownership, consulting, intellectual property development, outside employment, and commitment to external organizations. Institutional conflict of interest arises from financial interests of the university or senior officials that might color the review, approval, or monitoring of research.

It is important to note that potential conflicts frequently arise in university settings, often as part of legitimate professional development. Activities supported and encouraged by KU, such as consulting and commercialization of technologies represent the fulfillment of the university's mission to translate scientific discoveries into beneficial products and services, may arise as a potential conflict. For this an individual should not be concerned if their disclosures route for routine review. The more details an individual provides regarding the disclosures, the more quickly the COI office may complete their necessary review of the disclosed activities.

Types of Disclsoures:
eCompliance organizes disclosures within the following categories:
  • financial and managerial interests of Equity (e.g., ownership, stock holdings, equity interests, loans)
  • Remuneration (e.g. salary, consulting fees, commissions
  • Intellectual property rights and interests (e.g., patents, copyrights)
  • Sponsored travel (travel which is paid on behalf of the individual and not reimbursed to the individual so that the exact monetary value may not be readily available)
  • Outside professional positions, paid or volunteer (e.g., board position, consulting)
Such disclosures apply to: Faculty and unclassified staff, and other investigators on sponsored projects. Additionally, individuals must report significant financial interests of immediate family (spouses and children) and other household members.
 
Review and Management of Disclosures:  If there are disclosures that trigger a potential conflict of interest, an assigned committee reviews the disclosures in order to make a determination that may include a management plan. Once developed, the management plan goes to the department for oversight and implementation.

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What is a conflict of time commitment?

Conflict of time commitment exists whenever a faculty or staff member's external activities exceed reasonable time limits or whenever an unclassified staff or faculty member's primary professional responsibility is not to the University.

Standards for reporting: External time commitments should be reported if they relate to university responsibilities. These include consulting, outside employment, public service, pro bono work, or service as an officer in an external entity.
 
Applies to: Faculty and unclassified staff. 

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How often is filing required?
Reports must be filed: 

  • upon employment
  • annually in the fall, upon announcement from the Research Integrity office
  • upon submission of a PHS-compliant research proposal on which you are considered an investigator, and
  • on an ad hoc / update basis as financial interests are acquired.
Ad hoc / update reports: University policy requires ad hoc reporting of any new financial interest that meets the criteria for significance. These interests should be reported in an “Update Certification” as soon as they become known. to, government regulations require that the newly-disclosed conflict related to federally funded research be managed, reduced, or eliminated, at least on an interim basis, within sixty (60) days of its identification.
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What's new in the COI Reporting process? For most Faculty and Unclassified Staff members:
The University must be in compliance with the new Public Health Service (PHS) regulations, "Promoting Objectivity in Research," as of August 24, 2012. The major changes from the 1995 regulations include lower financial disclosure thresholds, increased transparency for travel reimbursement.

What's new in the COI Reporting process? For PHS-Sponsored Researchers:
The University must be in compliance with the new Public Health Service (PHS) regulations, "Promoting Objectivity in Research," dated August 24, 2012. There are three procedural changes applicable to investigators on PHS-compliant projects that will require your attention and participation.

1. Financial Conflict of Interest (FCOI) Training. As of 8/24/12 award funds for PHS-compliant project must be withheld until all investigators on the project have been trained. To satisfy the training requirement, KU has produced an online tutorial that takes about 45 minutes to complete. If you are an identified investigator, you will receive an e-mail from kucoisys@ku.edu with a link to the KU tutorial. Please complete the tutorial as soon as possible to ensure that your award funds are not delayed. On completion, your training will be certified for four years.
 
2. Certification of disclosed financial interests per PHS-compliant project. As of 8/24/12, each Investigator on a PHS-compliant project will also need to submit a special conflict of interest certification ("Research Certification") prior to each PHS-compliant proposal submission, or prior to the availability of funds for PHS-compliant projects pending or renewing the award.
 
Research Certification process: After a PI initiates contact with pre-award staff about a proposal or renewal submission, pre-award staff will generate an e-mail that contains a link to the new COI reporting system to each Investigator on the project. All Investigators must submit their certifications in the online system before the proposal is submitted.
 
3.PI decides who is an Investigator. The FCOI training and per-project Research Certification requirements apply to all "Investigators" on PHS-compliant proposed or funded projects. The PI is responsible for identifying individuals who will be participating at the Investigator level on the project.
 
While the federal definition of Investigator, below, is quite broad, keep in mind that its application to an individual is dependent on the individual's contribution to the project and may not apply to everyone named on the project.
 

What are the PHS–compliant agencies?
For your information, the current list of PHS-compliant agencies, as of 9/15/2015:

Public Health Service (PHS) Agencies
(updated 9/15/2015)

  1. Agency for Healthcare Research and Quality (AHRQ)
  2. Agency for Toxic Substances and Disease Registry (ATSDR)
  3. Centers for Disease Control and Prevention (CDC)
  4. Food and Drug Administration (FDA)
  5. Health Resources and Services Administration (HRSA)
  6. Indian Health Service (IHS)
  7. National Institutes of Health (NIH)
  8. Office of Global Affairs (OG)
  9. Office of the Assistant Secretary for Health (OASH)
  10. Office of the Assistant Secretary for Planning and Evaluation
  11. Office of the Assistant Secretary for Preparedness and Response (ASPR)
  12. Office of Public Health and Science
  13. Substance Abuse and Mental Health Services Administration (SAMHSA)

Non-PHS Agencies
(updated 3/10/2015)

  1. Alliance for Lupus Research (ALR)
  2. Alpha-1 Foundation
  3. American Asthma Foundation
  4. American Cancer Society (ACS)
  5. American Heart Association (AHA)
  6. American Lung Association (ALA)
  7. Arthritis Foundation (AF)
  8. CurePSP
  9. Juvenile Diabetes Research Foundation (JDRF)
  10. Lupus Foundation of America (LFA)
  11. Patient-Centered Outcomes Research Institute (PCORI)
  12. Susan G. Komen for the Cure

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What forms are filed?
The KU COI Reporting system asks individuals to certify whether they, their spouse, or other household members have any substantial interest or time commitment related to their own research or educational activities. The majority of employees have no significant financial interests to disclose, and the Certification submission at the end of the process completes their report.

Individuals who have significant financial interests or time commitments related to their university responsibilities must disclose details. These disclosures are handled with utmost confidentiality throughout the process. The COI Administrator reviews for potential conflicts and next steps, which could entail review by the COIC Chair, review by the COI Committee, or determination that a management plan must be developed. The purpose of a management plan is to outline how the conflict will be eliminated or minimized and monitored.

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What does the supervisor's signature indicate?
"Supervisor Review Completed" as used in the COI Reporting System indicates that the supervisor has reviewed the individual's certification and agrees to the best of his or her knowledge that the filer is in compliance with the COI policy.

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What are the consequences of failing to comply?
Failure to comply with reporting and disclosure requirements for conflict of interest and time commitments may have the following consequences:
a. Individuals will not be allowed to submit internal or external grant applications until they have complied.
b. Failure to comply may result in disciplinary action.

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I've reported my consulting activities on my Conflict of Interest report. Does this satisfy the reporting and approval requirements of the KU Consulting Policy?
No. Approval for consulting is a separate process which is overseen by the Office of the Provost. The Regents and federal Conflict of Interest reporting requirements in no way change the existing Regents or KU Consulting Policies or the responsibility of each faculty or unclassified staff member to follow reporting and approval procedures regarding consulting.

Standards for reporting: Information and forms for approval of consulting and other outside work are available on the policies and resources page of the Office of the Provost website.

Applies to: Faculty and unclassified staff.

Overseen by: The Office of the Provost.

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My grant application form contains a conflict of interest certification. If I've certified that I have no conflict of interest on a grant proposal, do I still need to submit a Conflict of Interest report?
Yes. Individuals who submit grant applications must certify that they understand and have complied with the Conflict of Interest policies. Your signature on the certification form indicates that your financial interests and time commitments have not changed since your most recent conflict of interest report. Certification for grant submission is not a substitute for Conflict of Interest reporting.

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What is the difference between the State of Kansas Statement of Substantial Interests and Board of Regents Conflict of Interest Reporting?
For many years, state employees with certain kinds of responsibilities have been required to file an annual State of Kansas Statement of Substantial Interests (KS SSI) in accordance with the laws administered by the Kansas Secretary of State. More information about the KS SSI is available on the Kansas Governmental Commission website.

In 2006, the Kansas Legislature approved a change in the scope of state employees required to file the KS SSI. As a result, many KU faculty were required to file the statement for the first time in the spring of 2006. These are two separate reporting requirements. Having filed a KS SSI does not change faculty or staff obligation to file a COI declaration at least annually.

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