Frequently Asked Questions
Disclosures are to be submitted in myCOI, part of the myResearch suite. myCOI will be used for the entire campus community (employees and researcher) beginning mid-February 2023.
The COI module of eCompliance is an online system that also stores the IRB, shared among the three campuses at KUMC, KUSM-Wichita and KU in Lawrence at https://ecompliance.ku.edu.
It will be retired for COI disclosure purposes on January 20, 2023
If you believe your access issue is due to username or password issues (particularly if you are a non-employee), contact the University IT Service Desk: Kansas City 913-945-9999 Option 2; Wichita 316-293-2605 or firstname.lastname@example.org.
Otherwise, contact Research Administration Systems Support: email@example.com for assistance.
After a new hire's information has been entered into the HR database, an Annual COI Certification will be created, and an e-mail will be sent to the new employee via eCompliance (firstname.lastname@example.org). This is until January 20, 2023. Afterward, an email will be prompted from the myCOI system. This process typically takes a day or two for faculty and unclassified staff. Allow for additional time for Student employees (eg GRAs) and temporary staff.
Since the individual has student status, the account is already in the system and probably just needs to be enabled. Send the student's name to email@example.com. The account will be enabled, a COI certification will be created, and the system will send the student an e-mail with the link to the certification.
Access to the data is limited. Regulatory staff (IRB, Research Administration and KUCC CTO) and certain department administrators and research coordinators have permissions within the COI disclosure system which allows them to access this information. Other administrators may have access to a Qlikview Report which contains compliance related to data. If you cannot identify such person, you may contact the COI Office
Please visit the COI Committee page located on the intranet (log-in required) for information about the COI Committee’s responsibilities and membership.
"Conflict of interest" refers to situations in which financial or managerial interests or time commitments may compromise, or have the appearance of compromising, scientific judgment, integrity of research data, fulfillment of professional duties, or the safety and welfare of research volunteers. A conflict of interest depends on the situation and not on the character or actions of the individual.
Conflicts can be individual or institutional in nature. Individual conflict of interest may be associated with financial incentives in research, business ownership, consulting, intellectual property development, outside employment, and commitment to external organizations. Institutional conflict of interest arises from financial interests of the university or senior officials that might color the review, approval, or monitoring of research.
It is important to note that potential conflicts frequently arise in university settings, often as part of desirable and legitimate professional development. Activities such as consulting and commercialization of technologies represent the fulfillment of the university's mission to translate scientific discoveries into beneficial products and services. KUMC encourages interactions that promote public benefit while ensuring the integrity with which those activities are accomplished.
Standards for reporting: financial and managerial interests of:
- Equity (e.g., ownership, stock holdings, equity interests, loans)
- Remuneration (e.g., salary, consulting fees, commissions)
- Intellectual property rights and interests (e.g., patents, copyrights)
- Sponsored travel (travel which is paid on behalf of the individual and not reimbursed to the individual so that the exact monetary value may not be readily available)
- Outside professional positions, paid or volunteer (e.g., board position, consulting)
Conflict of time commitment exists whenever a faculty or staff member's external activities exceed reasonable time limits or whenever an unclassified staff or faculty member's primary professional responsibility is not to the institution.
Standards for reporting: External time commitments should be reported if they relate to university responsibilities. These include consulting, outside employment, public service, pro bono work, or service as an officer in an external entity.
The federal definition of Investigator is "the project director or principal Investigator (PD/PI) and any other person, regardless of title or position, who is responsible for the design, conduct, or reporting of research funded by the PHS, or proposed for such funding, which may include, for example, persons who are subgrantees, contractors, consortium participants, collaborators, or consultants."
Kansas Board of Regents and KUMC policies require conflict of interest reporting by all full and part-time faculty and unclassified staff and other individuals who are responsible for the design, conduct, or reporting of research, and certain sub-recipients of sponsored projects or awards from PHS compliant agencies.
Reports must be filed:
- upon employment,
- annually thereafter,
- upon submission of a PHS-compliant research proposal on which you are considered an investigator, and
- on an ad hoc / update basis as new situations arise.
Ad hoc / update reports: Regents policy requires ad hoc reporting of any new situations that may raise questions about conflict of interest. These activities should be reported as soon as they become known. If the issue pertains to federally funded research, government regulations require that the newly-disclosed conflict be managed, reduced, or eliminated, at least on an interim basis, within sixty (60) days of its identification.
For Annual COI and COI upon employment, you will receive an email from the reporting system. It will contain a link to your COI reporting form or certification.. Use your KUMC network credentials to log in.
For ad hoc / updates, log into the myCOI and use the Edit Disclosure Profile button on the COI tab under Disclosures.
Detailed instructions for completing the form and navigating the system are found on the User Guidance link on the COI website.
Employees are asked to report activities and financial interests to the University and to their supervisor, chair or dean per the Kansas Board of Regents. The Office of Integrity & Compliance is responsible for managing this process, but it relies upon the supervisor to make assessments of the appropriateness of an activity and activities as a whole as supervisors are most familiar with the responsibilities and duties of their employees and the potential conflict which certain activities can pose to the department, unit or school.
Guidance is available to assist you in conducting this review. See the Checklist for Supervisor Review of Conflict of Interest/Commitment Disclosures on the COI Website's User Guidance page.
The University must be in compliance with the Public Health Service (PHS) regulations, "Promoting Objectivity in Research," by August 24, 2012. You may be listed as an investigator on a currently funded or proposed project sponsored by an agency that has adopted the PHS regulations (hereafter "PHS-compliant" agency). These requirements include.
- Financial Conflict of Interest (FCOI) Training. Training is separate from disclosure. See the Training for PHS Compliant studies for more detail.
- Certification of disclosed financial interests per PHS-compliant project. Each Investigator on a PHS-compliant project will also need to submit a disclosure profile update when receiving PHS-compliant notice of award. At proposal submission you will receive a notice which will remind you that disclosures must be current at time of submission. Research Project COI Certifications and notification reminders will be triggered by Research Administration staff
For clinical researchers:
Certain individuals (eg, principal investigators and co-investigators) on projects submitted to the IRB will be asked to submit a disclosure profile update prior to being approved by the IRB. This process will be finalized once the IRB system is integrated into myResearch.
The Research Institute will assist you. Call the main line at 913-588-1261 and request COI training or recertification proof for the researcher.
For many years, state employees with certain kinds of responsibilities have been required to file an annual State of Kansas Statement of Substantial Interests (KS SSI) in accordance with the laws administered by the Kansas Secretary of State. More information about the KS SSI is available on the Kansas Governmental Commission website.
In 2006, the Kansas Legislature approved a change in the scope of state employees required to file the KS SSI. As a result, many KU faculty were required to file the statement for the first time in the spring of 2006. The Conflict of Interest Certification and the Statement of Substantial Interests are two separate reporting requirements. Having filed a KS SSI does not change faculty or staff obligation to file a COI declaration at least annually.