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Research Responsibilities and Compliance

Disclosure Process

2022 Annual Disclosure

The 2022 annual disclosure period began on April 18, 2022, with the required one-year look back disclosure period going back to April 18, 2021. Faculty, staff, and students should complete the Disclosure Form by May 18, 2022.

Disclosure Process

On May 19, 2022, the Board of Trustees approved the Outside Activities and Conflicts policy with an effective date of September 1, 2022. The single, comprehensive policy combines four previous policies addressing university ethical expectations, research conflicts of interest regulations, and other federal and state laws governing financial and fiduciary conflicts of interest. The policy requires both pre-approval and disclosure of Outside Activities. Ohio State’s Annual Disclosure Process, completed in the electronic conflict of interest (eCOI) application, serves to satisfy this disclosure requirement.

Who is Required to Disclose

In keeping with the institutional obligations to comply with federal COI regulations, accreditation requirements and Ohio State policies, the following individuals are required to complete the Disclosure Form:

Faculty, staff members, administrators, and students who

  • have been identified as a project director, principal investigator, co-investigator, or senior/key personnel (including non-university employee consultants) on sponsored projects during the past 12 months
  • 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
  • received salary support during the past 12 months from specific federal grants or industry-sponsored projects, which require COI reporting
  • have been identified by the college or unit as having a fiduciary and financial responsibility

How to Disclose

To submit the Disclosure Form, follow the steps below.

  • Login to the electronic conflict of interest (eCOI) application https://go.osu.edu/coi using your Ohio State credentials.
  • On the eCOI homepage, click the “Disclosure Form” button to begin your Disclosure Form. Alternatively, you may click the “Disclosure Forms” tab from the menu bar, then select the current year’s Disclosure Form from the drop down.
  • Additional information is available by clicking the “Instructions” tab from the menu bar.
  • For technical assistance accessing or submitting the Disclosure Form or if not affiliated with The Ohio State University, contact the ORIS Help Desk.
  • For regulatory or procedural questions please contact ConflictInfo@osu.edu.

What to Disclose

It is required to disclose Outside Activities, financial interests, and other relationships from the past year that are related to—but not part of—job at Ohio State. These activities can be of own or those of an immediate family member, and may involve companies (small or large), non-profit organizations, or foreign governments/universities. In general, this includes the following types of activities:

  • receiving financial renumeration from an outside organization, including consulting, advising, or speaking activities; reimbursed or sponsored travel; and royalties, gifts, employment or other personal payments
  • holding equity, ownership, or investments in an outside organization
  • conducting research as a personal consultant or serving as a principal investigator outside of Ohio State
  • serving in any role or holding a title (e.g., Officer, Board of Directors Member) with decision-making authority in an outside organization
  • paid or unpaid foreign affiliations or research support from a foreign organization

In limited situations, it is also necessary to disclose activities that are unrelated to job at Ohio State. The Disclosure Form will ask this question.

As a part of the Disclosure Form, complete an “Outside Activities Screening” to help determine if any activities need to be disclosed. If answer is “Yes” to any of the screening questions, then it is required to disclose that activity. The Disclosure Form will prompt to both disclose that activity and provide details regarding the nature of the activity. Tips for Disclosing, Common Disclosure Scenarios and a list of What Not to Disclose are also available to assist you in determining what to disclose, and what not to disclose.

When in doubt, disclose—and err on the side of over-disclosure. Remember that disclosing promotes transparency and does not necessarily mean there is a conflict of interest. When conflicts do arise, they can often be managed.

How and When to Update the Disclosure Form

To update the Disclosure Form, follow the steps below. 

  • Login to https://go.osu.edu/coi using your Ohio State credentials.
  • On the eCOI homepage, click the “Disclosure Form” button to view your Disclosure Form. Alternatively, you may click the “Disclosure Forms” tab from the menu bar, then select the current year’s Disclosure Form from the drop down.
  • Click the “Modify Disclosure” button to re-open and update your Disclosure Form.
  • After updating your Disclosure Form, click the “Submit Disclosure” button located on the “Overview & Confirmation” page. Your revised Disclosure Form will then be routed for review.

Researchers are required to update the Disclosure Form within 30 days upon acquiring or discovering new financial interests, engaging in new Outside Activities, or changes in a previously reported activity. 

Also, researchers must report any reimbursed or sponsored travel that is not paid for or reimbursed with Ohio State funds or sponsored project funds within 30 days.

Obtain Previous Disclosure Forms

  • Login to https://go.osu.edu/coi using your Ohio State credentials.
  • Click the “Disclosure Forms” tab from the menu bar and then select “Previous Disclosures” from the drop down.
  • Click "View" to review the relevant Disclosure Form. Click "Download PDF" to save the form to your computer.

Review of Disclosure Forms

For research purposes

  • If any of the disclosed activities constitute a Significant Financial Interest (SFI) as defined by university policy, the Disclosure Form is reviewed by the researcher's department chair or college dean.
  • After the department or college signs, then the Disclosure Form is routed to the Office of Research Compliance for additional review.  
  • If an SFI may be related to a specific research project, then the Conflict Approval Committee (CAC) will determine whether a Financial Conflict of Interest (FCOI) exists. 
  • If an FCOI is found, then the CAC will recommend the development of a formal Conflict Management Plan (CMP) 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 Ohio State Wexner Medical Center employees with administrative/fiduciary/physician roles

  • If any of the disclosed activities could result in a potential conflict of interest the Disclosure Form may be reviewed by the Office of University Compliance and Integrity or the Office of Medical Center Compliance. 
  • The activity may be evaluated based on the disclosed entity’s vendor status, type of interest disclosed, and/or the employee's role at the university with the external entity. The employee may be contacted for more information by the Office of University Compliance and Integrity or the Office of Medical Center Compliance.