FAQs

Who has to file a Conflict of Interest (COI) Disclosure form?

The Ohio State University requires certain faculty, staff members, and students to complete an annual financial disclosure to comply with federal conflict of interest (COI) regulations, accreditation requirements, and OSU faculty and staff COI policies.  The following faculty, staff, and students are required to complete the 2017 eCOI disclosure form:

Faculty:

  • who have been identified as a project director, principal investigator, or senior/key personnel (including non-university employee consultants) on sponsored projects during the past 12 months;
  • who are investigators, senior, or key personnel on current Institutional Review Board (IRB), Institutional Animal Care and Use Committee (IACUC), or Institutional Biosafety Committee (IBC) protocols during the past 12 months;
  • who received salary support during the past 12 months from specific federal grants or industry-sponsored projects, which require COI reporting;
  • who have fiduciary and financial responsibility for their units, college, or the university; and/or
  • Member physicians of The Ohio State University Faculty Group Practice.

Staff members, Administrators, and Students;

  • who participated as investigators, senior or key personnel on sponsored projects during the past 12 months;
  • who are investigators, senior or key personnel on current IRB, IACUC, or IBC protocols during the past 12 months;
  • who received salary support during the past 12 months from specific federal grants or industry-sponsored projects, which require COI reporting;
  • who have fiduciary and financial responsibility for their units, college, or the university; and/or
  • select staff from the OSU Wexner Medical Center.

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How do I file my COI Disclosure?

Please use your university credentials to log-in to the electronic COI disclosure (e-COI) application, located at http://go.osu.edu/coi.  Additional information is available under the “Instructions” tab of the application.

For technical assistance with accessing e-COI or if you are not affiliated with The Ohio State University, please contact the ORIS Help Desk.

For regulatory or procedural questions please contact ConflictInfo@osu.edu.

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When do I have to file my new COI Disclosure?

The 2017 e-COI disclosure process begins April 17, 2017. Faculty, staff, and students should file their 2017 e-COI disclosures before May 17, 2017.

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I am new to Ohio State.  Do I need to disclose financial interests I acquired before joining the University?

Yes, federal research regulations require the disclosure of any financial interests (e.g., employment or consulting payments) from the previous 12 months that could be related to your institutional responsibilities.  When completing your disclosure form, you can indicate whether the only income you or your family member received in the past year was employee compensation received prior to beginning your Ohio State University employment.

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When do I have to update my COI Disclosure?

The federal COI regulations and university policy require faculty, staff, and students to update their e-COI disclosure within 30 days of receiving any new financial interest with an outside entity, or within 30 days of any changes to a currently-disclosed financial interest.   See the FAQ “How do I update my COI Disclosure?” below for more information.

Also, faculty, staff, and students must report any reimbursed or sponsored travel that is not paid for or reimbursed with The Ohio State University funds or sponsored project funds within 30 days.  See the FAQ “Does sponsored or reimbursed travel need to be disclosed?” below for more information.

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How do I update my COI Disclosure?

Please keep your eCOI disclosure form updated throughout the year by following the below steps.  Additional information can also be found in the Step by Step Instruction Guide for using eCOI application.

  • Log in to http://go.osu.edu/coi using your OSU Internet username (name.#) and password.
  • Once signed-in, click the “Modify Disclosure” button to re-open and update your disclosure form.
  • After updating your form, click the “Submit Disclosure” button located on the “Overview & Confirmation” page. Your revised COI disclosure form will then be routed for review.

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How do I get a copy of previous years disclosure forms?

  • Log in to http://go.osu.edu/coi  using your OSU Internet username (name.#) and password.
  • Once signed-in, click “My Disclosures” on the ribbon located at the top of of the screen.
  • You may view and download PDF copies of your previous disclosure forms.

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What types of financial interests do I have to report?

You must report all personal financial interests from external sources, including travel, that could be reasonably appear to relate to your institutional responsibilities at the university. This would include any interest in a company, business, foundation or other organization that:

  • Provides products or services in your academic, clinical, or research discipline or area of study. An example would be a manufacturer that has products in your  professional discipline, clinical practice area, or area of research;
  • Will likely make use of your scholarly work or research – either directly or indirectly.  For example, could the company, foundation or organization use your scholarly work or research in its own product line, or could it be used by a competitor?
  • Is a member of an industry, trade, advocacy group or professional association that funds scholarly work, research or is an advocate for funding in your professional discipline or area of study or expertise;
  • Has some other relationship not described above that could reasonably appear to impact your research or other obligations to the University;
  • You receive royalties directly from intellectual property that you have licensed to an external entity.

Note: For all disclosed consulting activities, faculty should have a current consulting approval form on file with their department, as required by the Faculty Paid External Consulting Policy. Similarly, staff should have an approved staff external work request form on file with their units, as required by the Staff Conflict of Interest and Work Outside the University Policy.

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Am I required to disclose passive investments (e.g., retirement accounts, mutual funds)?

Maybe, but only if you have direct control over the investment decisions made in these vehicles.

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For research purposes, what is meant by “financial interest” and “significant financial interest”?

A “financial interest” is any monetary value that belongs to you, your spouse or partner, or your dependent children. The financial interest becomes “significant” if it meets ANY of the following conditions:

  • All income from a publicly-traded entityreceived during the 12 months prior to disclosure plus the value of any equity interest in the entity as of the date of an annual disclosure, when combined, exceeds $10,000 or represents more than 5% ownership interest in any single entity. Examples of income include consulting fees, honoraria, or paid authorship. Equity interest includes any stock, stock option, or other ownership interest;
  • ANYequity interest held in a non-publicly traded entity, or more than $10,000 in income from a non-publicly traded entity received during the 12 months prior to disclosure; or
  • Income from intellectual property rights and interests received from an entity other than The Ohio State University that exceeds $10,000 during the 12 months prior to disclosure.

Please note that the U.S. Public Health Service (PHS) and its agencies define a “significant” financial interest (SFI) at a lower level than do other federal agencies, such as the National Science Foundation, and the university’s longstanding level of $10,000 described above.

Specifically, if you have worked on PHS funded research in the past year, or expect to work on PHS-funded projects this year, a financial interest becomes “significant” if it meets ANY of the following conditions:

  • All income from a publicly-traded entityreceived during the 12 months prior to disclosure plus the value of any equity interest in the entity as of the date of an annual disclosure, when combined, exceeds $5,000. Examples of income include consulting fees, honoraria, or paid authorship. Equity interest includes any stock, stock option, or other ownership interest;
  • ANYequity interest held in a non-publicly traded entity, or more than $5,000 in income from a non-publicly traded entity received during the 12 months prior to disclosure; or
  • Income from intellectual property rights and interests received from an entity other than The Ohio State University that exceeded $5,000during the 12 months prior to disclosure.

PHS agencies include the National Institutes of Health (NIH), Food and Drug Administration (FDA), Centers for Disease Control and Prevention (CDC), Indian Health Service (IHS), Health Resources and Services Administration (HRSA), Substance Abuse and Mental Health Services Administration (SAMHSA), Agency for Healthcare Research and Quality (AHRQ), Centers for Medicare & Medicaid Services (CMS), Administration for Children and Families (ACF), or Administration on Aging (AOA).

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Are there financial interests that I don’t have to disclose?

Federal regulations and university policy do not require you to disclose the following types of financial interests:

  • Reimbursement or payment of travel paid by The Ohio State University, or covered by a sponsored program agreement managed through the Office of Sponsored Programs;
  • Royalties received from The Ohio State University for intellectual property owned by the university;
  • Royalties resulting from traditional academic publishing activities such as the publication of text books or other educational materials;
  • Any salary or other remuneration paid to you by The Ohio State University or an Ohio State physician or dental practice group.

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Do I need to disclose my service as National PI of a clinical trial?

If you serve as National PI in your personal capacity (i.e., not as an Ohio State researcher), then you must disclose the personal compensation you receive for these activities.

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Does sponsored or reimbursed travel need to be disclosed?

Faculty, staff, and students are required to disclose the occurrence of any reimbursed or sponsored travel paid for directly or reimbursed by an external entity.  However, this disclosure requirement does not apply to:

  • Any travel reimbursed, sponsored or paid for by a U.S. government agency, a U.S. higher education institution, a U.S. academic teaching hospital, medical center, or a U.S. research institute affiliated with a U.S. higher education institution; and/or
  • Any travel reimbursement or payment of travel made by The Ohio State University, a university college, department or unit, or travel covered by a sponsored program agreement managed through the Office of Sponsored Programs.

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Who determines if I have a potential conflict of interest?

For research purposes, if you disclose a “significant” financial interest with an outside entity, your e-COI disclosure is reviewed by your department chair or college dean, who determines if the significant financial interest may be related to your institutional responsibilities.  If s/he determines that the interest may be related, your e-COI disclosure is then routed to the Conflict of Interest Administrator and The Ohio State University Conflict of Interest Advisory Committee (COIAC) for review.  The COIAC determines whether a significant financial interest is related to a specific research project or protocol and, if so, whether the interest could directly and significantly affect the design, conduct or reporting of the research.

For University and OSU Wexner Medical Center employees with administrative/fiduciary/physician roles, if you disclose a potential conflict of interest, then your disclosure form may be reviewed by the Office of University Compliance and Integrity or the Office of Medical Center Compliance.

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What happens if I have a potential conflict of interest?

For research purposes, if it is determined that a significant financial conflict of interest exists that may directly and significantly affect the design, conduct or reporting of a specific  research project, then a formal Conflict Management Plan (CMP) is created by The Ohio State University Conflict of Interest Advisory Committee (COIAC) to manage, reduce, or eliminate the conflict.  All Conflict Management Plans are reviewed, approved, and monitored pursuant to university policy and applicable federal regulations.

For University and OSU Wexner Medical Center employees with administrative/fiduciary/physician roles, if you disclose a potential conflict of interest, then that interest may be evaluated based on the disclosed entity’s vendor status, type of interest disclosed, and/or your role at the university with the external entity.  You may be contacted for more information by the Office of University Compliance and Integrity or the Office of Medical Center Compliance.

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Are there university policies that address the types of outside activities that OSU faculty/staff can participate in?

Yes, the following policies govern outside activities that OSU faculty/staff can participate in:

For additional information please see the Office of Academic Affairs OAA Policies and Procedures Handbook.

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What is an Organizational Financial Conflict of Interest?

Organizational Financial Conflicts of Interest (OCOI) may emerge when the university (or its key leaders) have financial or proprietary interests in a company sponsoring human subject research. As necessary, The Ohio State University Conflict of Interest Advisory Committee (COIAC) will develop a formal Conflict Management Plan designed to manage, reduce, or eliminate the OCOI. These recommended plans will be provided to the Institutional Review Board for final approval.

For more information on OCOI (also known as Institutional COI, or ICOI), please see the Human Research Protection Program’s policy on Organizational Financial Conflicts of Interest.

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