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COI Quick Reference

Policy Presentation Slides

•  Brief Policy Overview PDF
•  InfoEd Process Changes PDF
•  FASIS Pages for COI Reporting PDF

•  View all slides from the Town Hall meetings PDF

SponsorS Affected By Regulations

•  Research Sponsors Subject to Northwestern’s Research Conflict of Interest (COI) Disclosure Requirements PDF

•  List of sponsors currently following PHS reporting policy

Note: This list is not limited to the following sponsors; more are expected to follow.

•  Public Health Service (PHS)
•  National Science Foundation (NSF)
•  American Heart Association (AHA)
•  American Cancer Society (ACS)
•  Juvenile Diabetes Research Foundation (JDRF)
•  Industry-sponsored Basic Research
•  Susan G. Komen Foundation
•  Alliance for Lupus Research
•  Arthritis Foundation

Disclosure Criteria

Select a question set below to view the related policy criteria regarding Significant Financial Interests (SFI), or download a PDF of all questions and criteria PDF .

•  Questions #1 and #2: Publically Traded Entities

With regard to any publicly traded entity, a SFI exists if 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 for the Investigator and members of his or her Immediate Family, exceeds $5,000. (Please note: The Feinberg School of Medicine has a $0 threshold.)

For purposes of this definition, remuneration includes salary and any payment for services not otherwise identified as salary (e.g., consulting fees, honoraria, paid authorship); equity interest includes any stock, stock option or other ownership interest, as determined through reference to public prices or other reasonable measures of fair market value;

1) Have you received remuneration from publically traded entities that meet the criteria above?
Provide: Entity Name, Sponsor Name (if known), Remuneration Date, Amount, & Reason for Remuneration

2) Do you have equity interests in any publically traded entities that meet the criteria above?
Provide: Entity Name, Date Acquired, Value, & Form of Equity Interest (e.g. stock, stock options)

•  Questions #3 and #4: Non-publically Traded Entities

With regard to any non-publicly traded entity, a SFI exists if the value of any remuneration received from the entity in the twelve months preceding the disclosure, when aggregated for the Investigator and members of his or her Immediate Family, exceeds $5,000 ($0 threshold for The Feinberg School of Medicine), or when the Investigator (or the Investigator’s Immediate Family Member) holds any equity interest (e.g., stock, stock option, or other ownership interest);

3) Have you received remuneration from non-publically traded entities that meet the criteria above?
Provide: Entity Name, Sponsor Name (if known), Remuneration Date, Amount, & Reason for Remuneration

4) Do you have equity interests in any non-publically traded entities that meet the criteria above?
Provide: Entity Name, Date Acquired, Value, & Form of Equity Interest (e.g. stock, stock options)

•  Question #5: Intellectual Property Rights & Interests

Intellectual property rights and interests (e.g., patents, copyrights), upon receipt of income related to such rights and interests. SFI does not include intellectual property rights assigned to the University or agreements to share in the royalties related to such rights.

5) Do you have any privately held Intellectual Property Rights and Interests that meet the criteria above?
Provide: Description of Intellectual Property, Nature of Interest, Amount, & Date

•  Question #6: Travel

For PHS-funded Investigators, SFI also includes the occurrence of any reimbursed or sponsored travel related to their University responsibilities (including that which is paid on behalf of the Investigator but not reimbursed to the Investigator so that the exact monetary value may not be readily available). Reimbursed travel expenses that are for the personal use of the Investigator and his/her immediate family also should be included.

This disclosure requirement, however, does not apply to travel that is reimbursed or sponsored by a federal, state or local government agency, a qualifying institution of higher education, an academic teaching hospital, a medical center or a research institute that is affiliated with an institution of higher education. The details of this disclosure will include, at a minimum, the purpose of the trip, the identity of the sponsor/organizer, the destination and the duration.

Provide: Name of Sponsor/Organization, Purpose of Trip, Destination, Travel Begin Date, Duration (days), Amount (if known), Estimated Amount (if unknown)

•  What is not included as a Significant Financial Interest according to this policy?

(1) Salary, royalties or other remuneration paid by the University to the Investigator if the Investigator is currently employed or otherwise appointed by the University;

(2) Intellectual property rights assigned to the University and agreements to share in royalties related to such rights;

(3) Income from investment vehicles, such as mutual funds and retirement accounts, as long as the Investigator does not directly control the investment decisions made in these vehicles;

(4) Income from seminars, lectures or teaching engagements sponsored by a federal, state or local government agency, a qualifying institution of higher education, an academic teaching hospital, a medical center or a research institute that is affiliated with a qualifying institution of higher education; or

(5) Income from service on advisory committees or review panels for a federal, state or local government agency, a qualifying institution of higher education, an academic teaching hospital, a medical center or a research institute that is affiliated with a qualifying institution of higher education.