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Research Responsibilities and Compliance

eCOI Disclosure Process

2022 Annual Disclosure

The 2022 annual disclosure period is scheduled to begin 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 eCOI disclosure form by May 18, 2022.

Disclosure Process

The eCOI Disclosure Process serves as the common disclosure form for multiple policies administered by the Office of Research Compliance, the Office of University Compliance and Integrity, and the Wexner Medical Center Compliance Office. Disclosure is required in addition to obtaining pre-approval for all Outside Activities under Office of Academic Affairs (for Faculty) and Office of Human Resources (for Staff) policies.

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 faculty, staff, postdoctoral researchers and students are required to complete the 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 the 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 the college or unit as having a fiduciary and financial responsibility

How to Disclose

To submit the eCOI disclosure form, 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 accessing or submitting the eCOI disclosure form 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.

What to Disclose

You are required to disclose Outside Activities performed in the past year that are related to—but not part of—your job at Ohio State. These Outside Activities can be your own or those of an immediate family member, and may involve companies (small or large), non-profit organizations, or foreign governments/universities. In general, Outside Activities include 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 Outside Activities that are unrelated to your job at Ohio State. You will be asked a question about this on your eCOI disclosure form.

As a part of your eCOI disclosure form, you will complete an “Outside Activities Screening” to help you determine if you have any Outside Activities that need to be disclosed. If you answer “Yes” to any of the screening questions, then you are required to disclose that Outside Activity. The eCOI disclosure form will prompt you to both disclose that Outside 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 you have a COI. When conflicts do arise, they can often be managed.

How and When to Update an eCOI Disclosure Form

Keep the 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 eCOI disclosure form will then be routed for review.

Federal COI regulations and university policy require researchers to update the eCOI disclosure form 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 Ohio State funds or sponsored project funds within 30 days.

Obtain Previous eCOI 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.
  • View and download PDF copies of previous disclosure forms.

Review of eCOI Forms

For research purposes

  • If any of the Outside Activities disclosed constitute a Significant Financial Interest (SFI) as defined by university policy, the eCOI disclosure is reviewed by the researcher's department chair or college dean.
  • After the department or college signs, then the eCOI disclosure is routed to the Office of Research Compliance for additional review.  
  • If an SFI may be related to a specific research project, then the Faculty COI Advisory Committee (COIAC) will determine whether a Financial Conflict of Interest (FCOI) exists. 
  • If an FCOI is found, then the COIAC 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 Outside Activities that could be a potential conflict of interest are disclosed, then the eCOI 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 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.