What is included when disclosing financial interests related to research?

  1. Whom do I contact?
  2. How do I know if I need to submit a financial interest disclosure form? When do I submit the form?
  3. How do I get started?
  4. What are the training obligations? Are educational resources available?
  5. How does the University determine if there is a conflict of interest related to research?
  6. Will I be monitored after I receive a management plan?
  7. What are my continuing obligations concerning conflict of interest?
  8. What are my responsibilities when using controlled substances?
  9. Relevant policies, procedures, and links.

1. Whom do I contact?

The Conflict of Interest Review Office provides oversight, systemic safeguards, and regulatory expertise in managing individual and institutional financial interests that could impact research and scholarly activities. In doing so, we support Emory investigators and scholars in maintaining integrity in their research efforts.
Phone: insert, Staff Directory
Website:
Add: RAS IRB, Reg Specialist if WCI…

2. How do I know if I need to submit a financial interest disclosure form? When do I submit the form?

All Emory investigators involved with research must disclose their Significant Financial Interests using the Investigator Financial Interest in Research Report component of the electronic Conflict of Interest (eCOI) system.
These reports must be completed:
·       At the time of initiation for the project
·       On an annual basis for the life of the award
·       At time of annual progress report
·       Twelve months after the Novice of Award, and/or
·       Twelve months after initiation of the project
 
Please note: Investigators must report Significant Financial Interests of their spouses, same-sex domestic partners, and dependent children as well as their own.

Investigators named on a proposal or subcontract who are not employed by Emory do not have access to the eCOI system. For federally funded studies they must complete the Statement of Intent to Establish a Consortium Agreement and submit it to OSP with the grant proposal. That form can be found under the Policies and Forms page of the Conflict of Interest Office website.

Detailed information regarding submission of financial disclosure forms, all requirements may be found on the Conflict of Interest website under Frequently Asked Questions.

3. How do I get started?

Emory's eCOI application is a University and Healthcare system-wide tool that helps to implement Emory's policies and procedures regarding financial interests and external activities. This application and reporting process is used by Emory University and Healthcare only.

Below is a list of quick guides that explain the importance of eCOI, how to navigate each section of the website and the disclosure process.
·                    About eCOI
·                    Accessing eCOI
·                    How to complete an Annual Certification
·                    How to complete an External Activity Report

4. What are the training obligations? Are educational resources available?

Investigators must receive training about Conflict of Interest policy when they begin research at Emory and again at least every 4 years thereafter. This training is currently part of the eCOI system and must be completed before you will be allowed to submit your next Investigator Financial Interest in Research Report or Annual Certification. You will receive notice whenever your training must be renewed.
 
The training module is embedded in the financial interest disclosure form, so you can complete the training and disclosure requirements simultaneously by logging in to the eCOI system with your Emory Network ID and password. 

5. How does the University determine if there is a conflict of interest related to research?

Institutional Responsibilities are defined by Emory Policy 7.7 (Policy for Investigators Holding a Financial Interest in Research) as activities related to an Investigator's Research, Teaching, Clinical, Administrative, or Professional Duties at Emory.
 
Each Investigator who holds a Significant Financial Interest Requiring Disclosure must report the existence and nature of the interest prior to submitting a formal proposal to any proposed sponsor of the Research, or, prior to conducting the Research, if the Research is internally funded. At the time of routing a grant or contract proposal for sponsored Research.
 
When you submit a proposal to the Office of Sponsored Programs, you will be asked whether any of your previously-disclosed financial interests are related to the project.  Then the Conflict of Interest in Research Office will review your research proposal and financial interest disclosure form to determine whether your financial interest(s):
·        Meet thresholds specified by federal regulation  and University policy
·        Could directly and significantly affect the design, conduct, or reporting of the research
 
If your financial interests meet these requirements, a conflict of interest (or the appearance of a conflict) may exist.

Add: 

6. Will I be monitored after I receive a management plan?

The Conflict of Interest in Research Office will annually monitor whether you are following the terms of your management plan.  All issued management plans are subject to monitoring.  Therefore, it is important that you be able to document your compliance.   For example, when you publish or present study results, retain any notices about your conflict of interest sent to journals, conference organizers, etc.

7. What are my continuing obligations concerning conflict of interest?

Each year of a grant or contract, an Investigator must update his/her Investigator Financial Interest in Research Report. The form must be updated at the time of the annual progress report, twelve (12) months after the notice of award, or the initiation of research, whichever date is earliest. 
 
This disclosure shall serve as the annual certification for Investigators who do not hold a faculty appointment.