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Research Requirements

The Conflict of Interest in Research policy requires training and disclosure before initiating and throughout the life a project. Questions about whether a specific project falls under the Conflict of Interest in Research policy should be referred to

Below is general information related to the Conflict of Interest in Research policy. More detailed information is available on these pages:

Applicability of Research Policy

What research is covered?

  • All federally funded research
  • All industry-sponsored research
  • Research sponsored by foundations or other organizations with COI terms and conditions
  • All research involving human participants and submitted to the IRB, regardless of funding source

See the list of Sponsors with COI Requirements for a list of foundations known to have COI requirements.

Who is required to follow this policy on the project?

Investigators must meet research-related COI training and disclosure requirements. Investigator includes individuals responsible for the design, conduct, or reporting of research, regardless of position or title. The Principal Investigator of a project is responsible for making the determination of what named personnel are Investigators.


  • Key Personnel are always considered Investigators by virtue of the definition of Key Personnel
  • Investigators may alsoinclude others (internal or external to Northwestern) who areindependently responsible for research design, conduct, or reporting (i.e., individual(s) who have the authority to make independent decisions about the direction of the research and the subsequent conclusions about the results and/or are likely to be authors on manuscripts or to present research findings)>
  • Investigators are not administrative personnel or individuals who perform routine, pre-defined, or incidental tasks related to the project

If an individual who is named on a project does not meet the definition of Investigator, that individual can be marked as "not an Investigator" on the COI Compliance Page in eDisclosure. Instructions for doing so are on the Change Investigator Status page.

What is required?

Prior to proposal submission:

  • All Investigators must have disclosed in the last 365 days
  • Investigators must have completed training within the last four years

Note that some sponsors have additional requirements at proposal time that we must follow. Our guide to COI requirements at proposal time has more information on what questions should be considered prior to routing a proposal to OSR for final review.

Prior to opening a chartstring:

  • Review of each Investigator on the project must be complete in eDisclosure. Check the COI Compliance page in eDisclosure to confirm this. Our guide to the COI Compliance page has instructions on gaining access and interpreting the COI Compliance page