FAQ's
- Why must a new form be filed with each new proposal?
Potential conflicts of interest are project-specific; therefore, a form must be filed with each new proposal. A single disclosure for all projects cannot capture the information we need to review and manage possible conflicts.
For example, if an investigator submits a proposal for a project sponsored by Company X and s/he has no financial or other interest in Company X, the “Report of Outside Interests Related to Research” (ROI) should indicate that there is no interest to disclose. If the same investigator then submits a proposal for a project sponsored by Company Z, and s/he owns stock in or receives consulting income from Company Z, the ROI for that particular project must disclose the interest. If the same investigator also submits a proposal to NIH, the relationship with Company Z must be disclosed if the company’s work (i.e., product, technology, service) can be considered “reasonably related” to the work of that particular project, as specified in the federal regulations.
- If an investigator has no financial interests, why can't s/he just specify “no” somewhere on the Proposal Routing Sheet?
There is still a great deal of confusion and misunderstanding about what constitutes a financial or other interest. Before implementing this process, we received disclosures when none should have been made and, more importantly, no disclosures when they SHOULD have been made. Sponsored Projects Services has been willing to assist in educating faculty by including the question on the Proposal Routing Sheet to remind investigators to think about their financial or other interests as related to each project, but SPS is not responsible for collecting or tracking this information; that responsibility lies with the VPR’s office.
It may be helpful to remember that this is a temporary process. When the electronic Kuali Research Administration system is implemented, faculty will be automatically directed to the COI questions as part of the submission process. Our current paper process mimics the questions that will be included in the electronic system.
- A faculty member receives compensation for reviewing textbooks. Is this compensation reportable?
If the company/entity providing the compensation isn’t funding a research project for the faculty member, then the review compensation doesn’t have to be disclosed on an ROI. The activity should be reported, however, in the Annual Conflict of Interest and Conflict of Commitment Report that will be submitted to the Department Head each year (between February 1st and March 1st).