Conflict of Interest
At the University of Kansas, integrity, transparency, and stewardship are essential to advancing our missions of teaching, research, and service. We value the trust placed in us by students, colleagues, sponsors, and the public, and we are committed to conducting university activities in a manner that is fair, objective, and accountable.
Conflict of interest reporting is an important part of that commitment because it helps identify, disclose, and manage circumstances in which outside interests or commitments could affect, or appear to affect, university decision-making, research, or professional responsibilities. By addressing potential conflicts openly and proactively, KU supports the credibility of its work and advances confidence in the institution and its people.
Conflict of Interest Reporting
Kansas Board of Regents policy requires all faculty and unclassified professional/academic staff of Regents institutions to file a conflict of interest report upon employment. New employees will receive an email that contains a link to the COI reporting system. In the KU COI reporting system, employees are required to declare whether they, their spouse, or other household members have any significant financial interest related to their own research, administrative or educational activities. Additionally, individuals report any time commitments outside their university responsibilities related to the same activities. See the COI FAQs page or COI policies page for further information regarding how to use the system and what financial interests or outside commitments must be reported.
KBOR also requires annual reporting of disclosures. Once a year, all faculty and unclassified staff members will receive an email requiring they review their disclosures (if any) in the confidential COI system and make any updates. Even if they have no disclosures, the employees must go into the system to update their report of no disclosures.
In addition to annual reporting, faculty and staff must complete an ad hoc update to their disclosure report within 30 days if their financial relationships change during the fiscal year. To update your disclosures throughout the year, log into the COI reporting system and make any necessary updates. Additionally, faculty and staff members who are identified as investigators on Public Health Services (PHS) proposed or funded projects may be contacted by Pre-Award Services or Research Integrity staff to initiate a research certification (see further explanation below)
Kansas Board of Regents policy requires all faculty and unclassified professional/academic staff of Regents institutions to file a conflict of interest report upon employment. New employees will receive an email that contains a link to the COI reporting system. In the KU COI reporting system, employees are required to declare whether they, their spouse, or other household members have any significant financial interest related to their own research, administrative or educational activities. Additionally, individuals report any time commitments outside their university responsibilities related to the same activities. See the COI FAQs page or COI policies page for further information regarding how to use the system and what financial interests or outside commitments must be reported.
KBOR also requires annual reporting of disclosures. Once a year, all faculty and unclassified staff members will receive an email requiring they review their disclosures (if any) in the confidential COI system and make any updates. Even if they have no disclosures, the employees must go into the system to update their report of no disclosures.
In addition to annual reporting, faculty and staff must complete an ad hoc update to their disclosure report within 30 days if their financial relationships change during the fiscal year. To update your disclosures throughout the year, log into the COI reporting system and make any necessary updates. Additionally, faculty and staff members who are identified as investigators on Public Health Services (PHS) proposed or funded projects may be contacted by Pre-Award Services or Research Integrity staff to initiate a research certification (see further explanation below)
Conflict of Interest Requirements for Public Health Service and Department of Energy Agencies
Training
All University research personnel who are engaged in projects sponsored by an agency of the Public Health Service (PHS), the Department of Energy (DOE) or by an entity that has adopted PHS rules regarding Financial Conflict of Interest must complete training in Conflicts of Interest. Training is an additional requirement to your disclosure of financial interest and time commitment certifications.
- Investigators, defined as "the project director or principal investigator (PD/PI) and any other person, regardless of title or position, who is responsible for the purpose, design, conduct or reporting of research funded by the PHS or DOE, or proposed for such funding, which may include, for example, persons who are sub grantees, contractors, consortium participants, collaborators or consultants."
- Affiliates and Collaborators from other institutions who are working on University projects may also be required to complete training. If the subrecipient or subcontractor is not a PHS or DOE compliant institution and has not signed a subaward accepting responsibility for oversight of COI requirements, then collaborators must demonstrate completion of COI training and disclosure through the University.
- Prior to engaging in research sponsored by a PHS or DOE Agency or PHS compliant entity;
- Institutional Financial Conflict of Interest policies change in a manner that affects Investigator requirements;
- An Investigator is new to an Institution; or
- An Institution finds that an Investigator is not in compliance with the Institution's Financial Conflict of Interest policy or management plan.
Financial Conflict of Interest Training must be completed through the CITI Program and renewed every four years.
- Go to the CITI program website and click "Log in."
- Click "Log in through my institution."
- Choose University of Kansas-Lawrence from the SSO list.
- Log in with your KU online ID and password. If you have previously logged into CITI as a KU user, move to step 8.
- Click the "Continue" button.
- Select "I don't have a CITI Program account and I need to create one."
- Select "Click here to create a new CITI Program account." A CITI account will be created and linked to your KU-Lawrence or KUMC login info, and you will be able to log in using SSO in the future.
- On the main menu, make sure "University of Kansas-Lawrence" is selected.
- Click on the "Add a course" link to complete enrollment.
- Select question 4, Financial Conflicts of Interest (FCOI) courses. If you have never completed the FCOI training, select the "Initial KU Financial Conflicts of Interest" course. If you need to complete the 4-year retraining requirement, select the "Refresher KU Financial Conflicts of Interest" course.
- Scroll down and answer "Not at this time" for the remaining questions.
- Click the "Submit" button to complete registration; then complete the training.
Research Certifications
Each investigator must submit a special conflict of interest certification ("Research Certification") prior to each PHS-compliant proposal submission. This requirement must be completed for all investigators associated with the project prior to the
Research Certification Process
In consultation with the PI, pre-award staff will generate an email that contains a link to the COI reporting system to each investigator on the project. All investigators must complete their certifications in the myDisclosures system before the proposal is submitted.
Public Health Service Agencies
- Administration for Children & Families (ACF)
- Administration for Community Living (ACL)
- Agency for Healthcare Research & Quality (AHRQ)
- Agency for Toxic Substances & Disease Registry (ATSDR)
- Centers for Disease Control & Prevention (CDC)
- Food & Drug Administration (FDA)
- Health Resources & Services Administration (HRSA)
- Indian Health Service (IHS)
- National Institutes of Health (NIH)
- Office of Global Affairs (OG)
- Office of the Assistant Secretary for Health (OASH)
- Office of the Assistant Secretary for Planning & Evaluation
- Office of the Assistant Secretary for Preparedness & Response (ASPR)
- Office of Public Health & Science
- Substance Abuse & Mental Health Services Administration (SAMHSA)
Some non-PHS agencies have adopted the PHS regulations. Please consult directly with the private agency in question to clarify award terms.
Conflict of Interest Committee
Conflict of interest disclosures for the KU Lawrence campus are reviewed by a representative advisory committee, which makes a recommendation to the Vice Chancellor for Research and the Provost about the management of a conflict situation.
The Conflict of Interest Committee will consist of five faculty and unclassified staff members; a non-KU affiliate member; and ex officio non-voting members from the offices of the Provost, the Vice Chancellor for Research, and the Human Subjects Committee. Voting members are appointed by the Vice Chancellor for Research and serve rotating three-year terms. The Conflict of Interest Committee is not a policymaking body but can make policy recommendations.
Committee members or designated staff review each conflict of interest disclosure submitted and make recommendations as to whether an actual or perceived conflict of interest exists. The Conflict of Interest Committee may request additional information as necessary.
Conflict of Interest Committee recommendations are forwarded to the Vice Chancellor for Research and the Provost for final approval of the disposition of each potential conflict of interest situation. All information provided to the Conflict of Interest Committee will be maintained in strict confidence.
Contact
coi@ku.edu