Frequently Asked Questions
1. Who needs to complete this disclosure form?
The new form will need to be completed by individuals who meet ANY of the following criteria:
- Anyone who is responsible for the design, conduct, or reporting of research as well as anyone listed as key personnel on sponsored projects or human subjects research
- Anyone with an University, Campus or School Leadership role (VPs, Provosts, Chancellors, Vice Chancellors, Deans, etc.)
- Full-time faculty
- School of Medicine part-time faculty
- Staff employees with the following HR position levels or higher: 4AD, RS4, AX4, DV4, FC4, HP3, IT4, PR4, SS4, SA4, Health Care Provider and Clinical Diagnostician.
- Anyone with signature authority on behalf of the University
- All fiscal officers
- University personnel authorized to conduct purchasing activities and influence or affect the process or outcome of any expenditures
- Anyone that is otherwise directed by their department or school to complete a form
2. Why is this disclosure form required?
Indiana University is an institution of public trust and consistent with our Principles of Ethical Conduct, we have an obligation to be objective and impartial in making decisions on behalf of the University. To ensure this objectivity, we are expected to:
- Prevent individual or institutional conflicts of commitment in their assigned duties for the University;
- Disclose potential conflicts of interest and adhere to any requirements created to manage or eliminate any conflicts of interest;
- Ensure personal relationships do not interfere with objective judgment in decisions affecting University employment or the academic progress of a Community Member or a student; and
- Ensure their assigned duties for the University receive their full effort, attention, and commitment.
This form also satisfies the requirement for disclosure of outside interests from researchers; as before, this will assist in meeting the university’s policy and federal regulatory requirement to reduce, manage, or eliminate potential conflicts of interest to protect the university’s design, conduct, and reporting of research.
3. Who decides if the information on the disclosure form represents a conflict?
The information will be reviewed and initially evaluated by University Compliance Office and the Office of Research Compliance in consultation with the Office of the Vice President and General Counsel, Department Chairs, School Deans, other leadership positions who have management responsibility, and Human Resources, as needed. Conflict of Interest/Commitment committees will be established to determine if a potential conflict exists and how to mitigate it.
4. What will happen to the information I enter on to the disclosure form?
The information will be stored in the Kuali system that has been vetted and approved by the University Committee of Data Stewards. Only authorized personnel, as referenced in question 3, will be permitted to access this information. This information will be used to evaluate whether any University policies involving conflict of interest, conflict of commitment, nepotism and relationships with outside entities apply.
5. When is the disclosure form required to be filled out?
PHS, NSF, and PHS like funding agency funded researchers were required to complete the research form by August 31, 2017. The combined form will need to be completed by all other researchers by March 31, 2018, if a disclosure has not otherwise been submitted since August 2017.
With the exception of researchers, the timelines for the initial form launches will vary at different schools and campuses. Please contact the University Compliance Office if you would like more details or further guidance on when those within your unit should complete the disclosure.
6. When do I need to update the form?
You will need to update the form an annual basis or within 30 days of a change to any existing outside interest(s) or acquiring a new interest.
7. What are the policies that require this new combined form?
The University policies include the following:
- Financial Conflicts of Interest in Research (ACA-74)
- Conflicts of Interest (HR 07-40)
- Conflicts of Commitment (HR 07-30)
- Conflicts of Commitment Involving Outside Professional Activities for Academic Appointees (ACA-29)
- Nepotism (UA-10)
- Appropriate Duties of Academic Employees (Ghost Employees) (ACA-42)
- State Conflict of Interest for Procurement Transactions (FIN-PUR-3.3)
- Purchasing Ethics (FIN-PUR-3.0) – Conflicts of Interest Disclosure Statements
- Gifts and Gratuities (FIN-PUR-3.4)
8. What if I don’t complete the form?
Any existing or new research funding or approvals may be withheld until the disclosure is completed and/or updated.
University Compliance will provide reports to the applicable Department Chairs, School Deans, Human Resources and the Office of the Vice President & General Counsel, as needed, for follow-up.
Violations of university policies, including the failure to avoid a prohibited activity or disclose a conflict of interest in a timely manner, will be dealt with in accordance with applicable university policies and procedures for university employees, which may include disciplinary actions up to and including termination from the university.
9. I completed the research form previously – is this different?
Yes. The new form includes the questions you may have previously answered on the research conflict of interest form along with new questions on conflict of commitment, non-research conflict of interest and related topics.
10. Can my administrative assistant complete this form on my behalf?
No. You must log in with your IU credentials to complete the form and certify the information you provided is accurate.
11. Next year will I have to re-enter the same information?
No. The Kuali system will retain your outside interest information so you will only need to review and update the information you have previously entered, along with any new questions that might be added.
12. If I have questions about how to complete the form, whom should I contact?
For inquiries that do not involve research conflicts of interest questions on the form, please contact the University Compliance Office at email@example.com or 317-274-2667.
For inquiries involving research conflicts of interest please contact the Office of Research Compliance Conflict of Interest Office.
13. If I am aware of a conflict that is not being managed, where should I report my concerns?
Please contact the University Compliance Office at firstname.lastname@example.org or 317-274-2667.
14. When will I be contacted after completing my form and who will contact me?
You will not be contacted after your form is completed unless additional information or further action is needed from you. If you are involved in research, you will receive a system notification once the form has been approved through the research COI process if you disclosed any outside entities.
15. Will I still need to complete a separate state conflict of interest form?
Yes, the online COI-C disclosure form does not replace the state conflict of interest dislcosure statement. If the state conflict of interest applies to you, you will still need to complete the COI disclosure statement. Consult the resources on the Office of the Vice President and General Counsel website for more details.