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Conflict of Interest

Completing a Disclosure

Link: Basic Steps Diagram

Who Must Disclose:

All Investigators must complete an annual Research-Related Financial Interest Disclosure form. Investigators include University faculty and staff who have responsibility for designing research, collecting research data, performing other substantive research activities, or reporting research. Investigator includes the project director or principal investigator and any other person, regardless of title or position, who is responsible for the design, conduct, or reporting of Research or Sponsored Programs which may include, for example, collaborators, consultants, students, non-paid volunteers and others. Research need not be funded for a person to be considered an Investigator. It is up to the PI to determine which research project personnel have responsibility for designing collecting or reporting research and are thus required to complete an annual Research-Related Financial Interest Disclosure. Additionally, anyone engaged in any sponsored program, whether or not involving research, must complete an annual disclosure form.

When to Disclose:

The research-related conflict of interest disclosure must be completed annually, or as soon as possible whenever interests change or new interests occur; including reimbursed or sponsored travel.
Also see Changes to Financial Interests

What to Disclose:

When you are completing your form, you must disclose a significant financial interest if it meets the following criteria within the past twelve months:

  1. With regard to any publicly traded entity, it is the value of any remuneration received from the entity in the twelve months preceding the disclosure and the value of any equity interest in the entity as of the date of disclosure, when aggregated, the value of which exceeds $5,000 from one enterprise or entity;
  2. With regard to any non-publicly traded entity, it is the value of remuneration received from the entity in the twelve months preceding the disclosure, when aggregated, exceeds $5,000, or when the Investigator holds any equity interest;
  3. Intellectual property rights and interests totally $5,000 or more, upon receipt of income related to such rights and interests;
  4. Salary, remuneration, reimbursed or sponsored travel or similar payments which exceed, or are expected to exceed $5,000 within any one-year period, when aggregated for the member and his or her Family Members; or

Note: Investigators need not disclose travel that is reimbursed or sponsored by a US federal, state, or local government agency, a US Institution of higher education as defined at 20 U.S.C 1001(a), a US academic teaching hospital, a US medical center, or a US research institution that is affiliated with a US Institution of higher education.

How to Disclose:

How to verify COI Completed: To verify if an Investigator has completed the COI Research-Related Financial Interest Disclosure form for the IUPUI and Columbus Campuses or for the Bloomington and Regional Campuses, please contact the respective COI Office via the 'Contact us' information to the left.


Basic Steps 1 & 2 Step 1: Completing a Disclosure Step 2: COI Disclosure ReviewCurrent Page
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