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Disclosure Tips  |  Documents & Resources  |  Upcoming Training Events

How do I disclose for the first time?

  1. Please click the following link and sign-in with your NetID & Password: Conflict of Interest Portal
  2. On the left-hand side of the screen, under “My Role,” select “Conflict of Interest”
  3. Click “COI Training for Research”
  4. Open and read the PDF document
  5. Attest to having read and understood the contents of the training document
  6. Once the Attest link has been clicked, a link will appear on the bottom left-side for access to the “COI Disclosure for Research”
  7. Answer the COI disclosure questions
  8. Click “Sign” and “Submit”

How do I disclose on an ongoing basis?

  1. Please click the following link and sign-in with your NetID & Password: Conflict of Interest Portal
  2. On the left-hand side of the screen, under “My Role,” select “Conflict of Interest”
  3. Select  “COI Disclosure for Research”
  4. Check your reason for disclosure
  5. Answer the COI disclosure questions
  6. Click “Sign” and “Submit”

Who must disclose?

Any individual acting as a “project director or principal investigator and any other person, regardless of title or position, who is responsible for the design, conduct, or reporting of research” is an Investigator, or "someone who assumes independent responsibility for portions of an Investigator’s proposed or funded project, which may include collaborators or consultants." Please refer to the policy for details.

What must be disclosed?

Any Significant Financial Interests (SFI), which means an external financial interest consisting of one or more of the following interests of an Investigator (and those of the Investigator’s spouse and dependent children), when combined for the 12 months preceding the disclosure date, from a single entity:

Nature of SFI Threshold Excluded (Do Not Disclose)
Compensation and/or other payments for service Exceeds $5,000* Compensation received less than $5,000, as well as any compensation received for lectures, seminars, teaching engagements, or service on advisory committees or review panels relating to federal, state, or local government agencies, an institution of higher education, an academic teaching hospital, a medical center, or a research institute that is affiliated with an institution of higher education, and compensation received from NU funds
Equity interests in a publicly-traded entity Exceeds $5,000* Interests in publicaly-traded entities valued at less than $5,000 as well as interests in any entity through personal retirement accounts and mutual funds
Equity interests in a non-publicly-traded entity 0 Interests in any entity through personal retirement accounts and mutual funds
Intellectual property rights and interests upon receipt of income related to such rights and interests Exceeds $5,000* Royalties received from NU funds, and unlicensed intellectual property that does not generate income
Sponsored or reimbursed travel

Applies to PHS-funded researchers only: Investigators who have any PHS funding or any funding from agencies following PHS COI regulations must disclose any reimbursed or sponsored travel		 Exceeds $5,000 Travel administered through NU funds, and travel reimbursed or sponsored by a federal, state, or local government agency, an Institution of higher education, an academic teaching hospital, a medical center, or a research institute that is affiliated with an Institution of higher education.
* Investigators whose primary appointment is in the Feinberg School of Medicine (FSM) are subject to different reporting thresholds. Please read each disclosure question carefully.

When Must I Submit a Disclosure?

Timing Disclosure Timeframe
New Proposal Within 30 days prior to grant submission date.
New Awards or
Just-in-time
Requests		 All Investigators must update disclosures upon request.
Continuation
Progress Reports		 At the time of progress report.
Anytime a New
SFI is Acquired		 Within 30 days from the discovery or acquisition of a significant financial interest (SFI); enter FASIS and choose "Update Disclosure" option.

* PHS-sponsored projects must update travel disclosures as they occur.

DOCUMENTS & Resources

Training Documents
FASIS Security Forms

To access the COI Monitor Compliance pages in FASIS, please complete and submit a Security Form for Research Administrators and other administrators who need access to compliance pages in FASIS: OSR/ASRSP/NUCOI Staff, or School COI Committee participants.

External Agency Resources

UPCOMING TRAINING EVENTS

There are no training events scheduled at this time. To request an in-person training, please contact nucoi@northwestern.edu. To request an in-person system training, please contact Chris Tondini at tondini@northwestern.edu.

Additionally, there is a COI session included in the quarterly ORI Research Administration Training Seminar.