Conflicts of Interest and Coordination of Information (COI COI)

Our annual conflict of interest (COI) disclosure period opened this month, so we are fervently reviewing nearly 6,000 disclosures. It is our third year of facilitating university-wide disclosures for all full-time employees. The first year was focused on making the disclosures. The second year was focused on getting management plans in place. This year we really began to think strategically about the information we were getting and how it impacts other units on campus.

For example, faculty are required to complete a form to obtain permission from the Provost's Office to engage in private consulting, which is approved by the faculty member's department head/chair and dean. As faculty disclose outside consulting and professional activity in the COI disclosure, we verify whether the appropriate consulting form has been submitted to the Provost. If it hasn't, we email the respondent with information about the consulting policy and related forms. This process serves both as policy enforcement (making sure the forms are being submitted) and education/training (what policy applies and what faculty must do to comply), further strengthening our compliance program.

Additionally, Sponsored Programs, the office that facilitates grant proposal submissions, needs to verify the principal investigator's potential conflicts prior to submitting the proposal to the sponsoring agency. Providing those officers with the necessary information and/or access to COI disclosures is vital to complying with sponsor regulations. Many federal agencies are placing more onus on the institution, not just the individual, to disclose and manage conflicts of interest related to research and sponsored activities. It is imperative that the right people have the right information to comply with sponsor requirements and reduce institutional liability.

Lastly, increased scrutiny on foreign influence in higher education by the U.S. federal government has prompted a heightened awareness of the issue at colleges and universities. Any COI disclosures involving foreign entities should be vetted by your Research Security Compliance team for collaborations with debarred entities, unauthorized transfers of scientific and technical information, or national security implications. Again, federal agencies expect institutions to be more proactive in this area to help mitigate the threat of foreign influence in U.S. research and development.

As you can see, real or potential conflicts touch many other departments on campus and overlap with other policies, processes, and procedures. Devising a way to streamline these and work collaboratively with other units to disclose and manage COI is an important part of being a proactive manager.

Kristin Roberts, JD, CCEP
Compliance Manager