Conflict of Interest & Conflict of Commitment (COI-COC)
The University of Chicago's Conflict of Interest/ Conflict of Commitment Policy requires that all Faculty and Other Academic Appointees complete the Conflict of Interest/ Conflict of Commitment Disclosure process. In addition, any individuals engaged in the design, conduct, or reporting of research at The University of Chicago must comply with the policy, which includes anyone who is permitted by virtue of their appointment at the University or by approval of the Provost's office to serve as Principal Investigator, and to other academic personnel or staff employees serving as "Investigators" or "Key Personnel" on research and other sponsored projects. This is a University-wide policy that is required regardless of whether Faculty receive external research funding through the University.
As of August 2012, The University's Conflict of Interest/ Conflict of Commitment Disclosure process was revised to capture both the new federal guidelines as well as The University of Chicago and The University of Chicago Medical Center requirements.
Subrecipients will complete the URA Disclosure Form for Subrecipients if they do not have a PHS (Public Health Services) compliant policy on Conflict of Interest.
Additionally, the regulation requires that individuals who receive PHS funding must show evidence of completing conflict of interest training, prior to the release of grant dollars.
Researchers who are subject to PHS conflict of interest reporting should log into CITI (Collaborative Institutional Training Initiative, www.citiprogram.org). This is the site previously used to complete RCR and human subject training.
See here for CITI Quick Reference Guide
Note: To facilitate compliance with applicable law, reporting obligations and institutional policies, information disclosed may be shared with officials and administrators responsible for conflict of interest/ conflict of commitment oversight at both The University of Chicago Medical Center and The University of Chicago.
Reminder on CITI –COI training
For Agencies following the PHS policy, CITI training is required at the time of proposal submission and for new awards, prior to award distribution in AURA. There are 3 CITI COI modules but there are many other CITI compliance modules. If these modules don't show up on log in, select the "add a course or update my learner groups" link from the main menu.
The following are the 3 required CITI-COI modules -
Conflicts of Interest, Stage 1:
- CITI Conflict of Interest Course - Introduction
- Financial Conflicts of Interest: Overview, Investigator Responsibilities, and COI Rules
- Institutional Responsibilities as They Affect Investigators
Questions about COI / Disclosure Process?
Susan Zonia, Director of Research Integrity, at email@example.com or (773) 702-4857
Kanae Eddings, Compliance Administrator, at firstname.lastname@example.org or (773) 834-0621.
Questions on AURA-COI or CITI: please contact email@example.com.