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New Kuali COI Research Related Disclosure Process

July 10, 2017

Beginning August, 2017 the Office of Research Compliance, Conflict of Interest (COI) Office will release a new Annual Research-Related Conflict of Interest Disclosure Form process.

What to Know About the New Kuali COI System and Process

Your COI disclosure information will now be entered into Kuali COI via, as with other Kuali research applications. The new Kuali COI disclosure system will maintain a history of your disclosure information and allow you to make updates to your financial interest information. After submitting your first disclosure in the new system, you will no longer have to re-enter your financial entity information each year.

Additionally, the new disclosure process allows for a rolling annual disclosure period rather than a static date. In the past, all annual research-related COI disclosures were required to be updated each August. In the new system, this will not be the case. Once you enter a disclosure, and if your disclosure information has not changed, your annual update will be due 365 days following your last disclosure approval. This means that whenever you update your financial entity information, as long as your financial interests have not changed, your disclosure will also update and renewal will not be needed until a full year from that last update.

As always, please note that if you have a new financial interest or your existing financial interest changes, you must update your research-related conflict of interest disclosure within 30 days in the new system. Again, this will reset the annual disclosure renewal clock to 365 days from that update.

How Will the New System and Process Be Rolled Out?

The COI Office will initially be sending out notification emails to only a subset of researchers for the August, 2017 roll-out in request to update their annual research-related COI disclosure.

This first subset of researchers will include anyone who is funded by a PHS (DHHS) agency, NSF, or other awarding agency that requires PHS FCOI compliance. Researchers will receive an email notification from the COI office with instruction on how to complete their research-related conflict of interest disclosure in the new Kuali COI system. Additionally, researchers who have never completed a COI disclosure, or have an update to be reported, will also be able to complete their research-related conflict of interest disclosure using the new Kuali COI system. Otherwise, remaining investigators will be required to update their COI disclosure information in the new Kuali COI later in the course of the 2017-2018 year. More information will be forthcoming when the remaining investigators will be required to submit their forms.

Below is a table to help clarify:

Disclosures Requiring Renewal Required When
Researchers funded by PHS (DHHS), NSF, or other awarding agency that requires PHS FCOI compliance;

Researchers with an update to their disclosure form from last disclosure period
August, 2017
Researchers who have not completed a disclosure previously;

Researchers who have an IU username, but completed a paper disclosure form in 2016-2017
August, 2017
or as requested by
the Compliance and
Grants Offices
All remaining researchers having previously disclosed Conflict of Interest (COI) with no change in outside interest from 2016-2017 Beginning 2018
All qualifying university Staff requiring disclosure of conflicts of commitment Beginning 2018

Future Plans

After the initial August release, there will be updates to the system in 2018 that will allow conflict of commitment disclosure information to be included in the annual disclosure process. Additional information will be sent out regarding these new features at a later date. If you would like more information on this effort, please visit University Compliance in the coming months for updates.


We look forward to providing this new process and the benefits it will offer!

If you have any questions about the new Kuali COI system or process, feel free to contact the COI Office:

-Bloomington and Regional Campuses: 812-856-1706 or

-IUPUI and Hospitals: 317-274-4894 or

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