1. Who needs to complete this disclosure form?
The 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 in the following job classification career levels and/or functions within any job family:
Levels Functions Advanced Development & Advancement Expert Finance Operational Sr. Operational Strategic Executive - 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
- All academic appointees and employees shall disclose to their unit head any situation in which the employee has a real or potential conflict of interest through the Conflicts of Interest and Commitment Disclosure 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 evaluated by unit heads in consultation with the University Compliance and Policy Office and the Office of Research Compliance. 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?
All individuals named in number 1 are required to submit an annual disclosure form in the Kuail COI-C system. Please contact the University Compliance and Policy Office if you would like more details or further guidance on when you or those within your unit should complete the disclosure. Please note that if you are utilizing the portal to disclose information to IU Health that you may be required by IU Health to submit on an alternate schedule. Annual compliance with the IU Health schedule will also satisfy your annual requirement for the university.
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 IU policy requires this new combined form?
The Indiana University policies below were recently combined into one Conflicts of Interest and Commitment policy (UA-17).
View the updated Conflicts of Interest and Commitment Policy (UA-17)
- 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 and Policy Office provides access to 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?
Yes, you can assign a delegate to complete portions of your disclosure form on your behalf.
- Open “Disclosures”
- Select “My Delegates”
- Select “Add Delegate”
- Type in the delegate’s IU username and select “Add”
- Inform delegate(s), via email or other form of communication outside of Kuali COI, they now have permission to edit your disclosure
- Use trash can button to the right of the user’s name to delete delegate.
- Users are responsible for managing their own delegate permissions.
- Delegates are unable to submit disclosures on behalf of their delegator. Individuals must review entries by their delegates and submit their own disclosure in Kuali COI system
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 and Policy Office at comply@iu.edu 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 and Policy Office at comply@iu.edu 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 disclosure 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.
16. I completed my disclosure; why is KC IRB and/or KC Grants showing that my COI disclosure is missing?
There are two possible reasons that your disclosure is not showing up in these systems:
- The first reason could be due to the roles you selected at the beginning of the form. You must select the second role of PI, co-investigator, or Key Personnel on any research/sponsored project having responsibility for the design, conduct, or reporting of IU research to get the research COI questions.
- The second reason is that your form is still In Progress and has not been submitted. When you log into Kuali COI, your dashboard will show your current disclosure status.
17. I completed my disclosure; why is my unit stating that my non-research disclosure is not complete?
There are two possible reasons that your disclosure is not showing as Up to Date.
- The first reason could be due to the roles you selected at the beginning of the form. You must select the first role of University employee, including faculty and academic employees, student academic appointees, and staff and temporary employees to get the general non-research conflicts of interest and commitment questions.
- The second reason is that your form is still In Progress and has not been submitted. When you log into Kuali COI, your dashboard will show your current disclosure status.