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Research Responsibilities and Compliance

Disclose a Conflict of Interest

2021 Annual Disclosure

The 2021 annual disclosure period begins on April 19, 2021, with the required one-year look back disclosure period going back to April 19, 2020. Faculty, staff, and students should complete their eCOI disclosure by May 19, 2021.

Disclosure Process

Who is Required to Disclose

In keeping with our institutional obligations to comply with federal COI regulations, accreditation requirements and Ohio State policies, the following faculty, staff, postdoctoral researchers and students are required to complete the an eCOI disclosure:

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
  • 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 their college or unit as having a fiduciary and financial responsibility

Staff members, Administrators, and Students who

  • participated as investigators senior or key personnel on sponsored projects during the past 12 months
  • are investigators, senior or key personnel on current IRB, IACUC or 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 their college or unit as having a fiduciary and financial responsibility

National Principal Investigator

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

How to Disclose

To submit a COI disclosure follow the steps below.

  • Login to the electronic COI disclosure (eCOI) application https://go.osu.edu/coi using your Ohio State credentials.
  • Additional information is available by clicking the “My Disclosure” tab and clicking the “Instructions” tab of the application.
  • For technical assistance with accessing eCOI or if you are not affiliated with The Ohio State University, contact the ORIS Help Desk.
  • For regulatory or procedural questions please contact ConflictInfo@osu.edu.

For anyone new to Ohio State, 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.

How and When to Update a COI Disclosure

Keep your eCOI disclosure form updated throughout the year by following the below steps.

  • Login to https://go.osu.edu/coi using your Ohio State credentials.
  • 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.

Federal COI regulations and university policy require researchers 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. 

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.

Obtain Previous COI Disclosures

  • Login to https://go.osu.edu/coi using your Ohio State credentials.
  • Once signed-in, click the “My Disclosure” tab at the top of the application screen and then click on the “Previous Disclosures” tab from the drop down listing.
  • You may view and download PDF copies of your previous disclosure forms.

COI Management

For research purposes, if you disclose a “significant” financial interest with an outside entity, your eCOI 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 eCOI 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. If it is determined that a significant financial conflict of interest exists, 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 Ohio State 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. The disclosure 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.