At Ohio State, as both a land-grant and R1 university, there is an obligation to uphold the highest standards of integrity and transparency. The annual conflict of interest disclosure process, in the eCOI application, is an opportunity to fulfill these obligations.
Four Disclosure Tips
Disclosure = Transparency
Full disclosure of outside activities, financial interests, and other relationships from outside Ohio State promotes the shared values of integrity and transparency.
Since disclosure requirements at the federal level are changing, ensure that all external collaborations are disclosed that are related to, but not necessarily part of, the filer's job at Ohio State, regardless of whether the filer is paid for the activity.
The Disclosure Form asks simple, direct questions to make it easy to properly disclose these activities.
Disclosure ≠ Conflict of Interest
It is important to understand that disclosure does not necessarily mean there is a conflict of interest. It simply means being transparent. The first tip, Disclosure = Transparency, recommends transparency 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 the activity:
- Is money going into my pocket?
- Am I personally benefiting from this activity even if I’m not receiving money?
- Would I be embarrassed if someone pointed out that I didn’t disclose this activity?
If the answer is yes to any of these questions, then that activity should be disclosed.
When in Doubt, Disclose!
It can be difficult to assess which financial interests and other relationships need to be disclosed—especially because Conflict of Interest (COI) policies often apply differently to faculty, staff, students, researchers, physicians and administrators.
Filers don’t need to know every aspect of COI laws, regulations and policies. When in doubt, simply 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 activities requiring disclosure. As a general rule, err on the side of disclosure. This includes disclosing paid or unpaid affiliations and appointments or other titles held outside Ohio State.
Keep on Disclosing (Early and Often)
Researchers, employees otherwise identified by their unit, including those who have financial or fiduciary responsibilities, college/regional campus deans, and President’s Cabinet members must complete a Disclosure Form annually.
When notified that this year’s Disclosure Form is open, take the time to fill it out early. If there is nothing to disclose, then take five minutes to say so. If there is something to disclose, then take a few extra minutes to do it. Ohio State recognizes everyone is busy and time is valuable. However, disclosure can save you time in the future and prevent a range of potential negative consequences. In addition, it is important to ensure that the Disclosure Form is accurate, and up-to-date throughout the year.