At Ohio State, as both a land-grant and R1 university, we have an obligation to uphold the highest standards of integrity and transparency. The annual conflict of interest disclosure process, known as eCOI, is an opportunity to fulfill these obligations. We have developed these four tips to help you understand the reporting requirements.
Disclosure = Transparency
Full disclosure of your outside activities promotes the shared values of integrity and transparency.
Since disclosure requirements at the federal level are changing, please ensure that you are disclosing all external collaborations that are related to, but not necessarily part of, your job at Ohio State, regardless of whether you are paid for the outside activity.
The disclosure form asks simple, direct questions to make it easy for you to properly disclose these “Outside Activities.”
Disclosure ≠ Conflict of Interest
It is important to understand that disclosure does not necessarily mean you have a conflict of interest. It simply means you’re being transparent. In the first tip, we talked about being transparent in the disclosure process regardless of whether an outside activity is paid or not. This means that disclosure is about much more than financial conflicts of interest.
Remember – think more broadly about disclosure. Ask yourself these simple questions about your “Outside Activities”:
- Is money going into my pocket?
- Am I personally benefiting from this “Outside Activity” even if I’m not receiving money?
- Would I be embarrassed if someone pointed out that I didn’t disclose this activity?
If you answer yes to any of these questions, then you have something that should be disclosed.
When in Doubt, Disclose!
It can be difficult to assess which “Outside Activities” need to be disclosed—especially because Conflict of Interest (COI) policies often apply differently to faculty, staff, students, researchers, physicians and administrators.
You don’t need to know every aspect of COI laws, regulations and policies. When in doubt, you simply need to disclose. For example:
- I’m a scientific advisor to a company, but they’re not paying me – disclose.
- I have options in a start-up company, but it’s only a piece of paper and not worth anything – disclose.
- I have an honorary appointment with a foreign university, but I don’t do anything with them – disclose.
These are examples of “Outside Activities” requiring disclosure. As a general rule, you should err on the side of disclosure. This includes disclosing paid or unpaid affiliations and appointments or other titles you hold outside Ohio State.
Keep on Disclosing (Early and Often)
When you are notified that this year’s disclosure form is open, please take the time to fill it out early. If you have nothing to disclose, then take five minutes to say so. If you have something to disclose, then take a few extra minutes to do it. We recognize you are busy and your time is valuable. However, disclosure can save you time in the future and prevent a range of potential negative consequences.
Then, keep disclosing throughout the year—because disclosure is an ongoing requirement for all of us. We’re obligated to update our disclosure forms when we participate in new “Outside Activities” or when circumstances change.
In practice, most university employees will only need to complete the disclosure form annually, especially if there is nothing to disclose. However, if you engage in ongoing or new “Outside Activities,” you will need to update the disclosure form throughout the year as things change. This includes disclosing activities performed during off-duty periods (e.g., summer, spring and winter breaks).