This page aims to provide answers to common questions about Conflicts of Interest (COIs) and COI regulations at NC State University.
If you have questions about how to fill out a COI disclosure form or have encountered an error within the COI system, please visit the COI System Help page for more information and assistance.
- ALL faculty (including adjunct faculty and emeritus faculty who are participating in a sponsored project)
- Postdoctoral scholars
- EHRA professionals paid from ANY source
- Graduate assistants (GAs) paid from ledger 5 (sponsored research) funds
- SHRA employees paid from ledger 5 (sponsored research) funds
- Research personnel engaged in the design, conduct, or reporting of a sponsored research project (e.g. part-time and temporary employees)
If you fall into one of the abovementioned categories (See “Who is required to complete a COI disclosure?”), you are REQUIRED to file a COI disclosure with North Carolina State University ANNUALLY in order to adhere University regulations. If your circumstances change, you must file a revised COI disclosure within 30 days of the change to notify the University accordingly. New covered employees must file a COI disclosure within 30 days of their start date.
COI disclosure periods run from August 16th through August 15th of each year. The current COI disclosure period began on August 16, 2017 and will end on August 15, 2018. The deadline for submitting this year’s annual COI disclosure was Friday, October 27, 2017. If you are included in one of the aforementioned categories and have NOT filed a COI disclosure since August 16, 2017, then be sure to submit your COI disclosure as soon as possible.
Yes. Annually, all employees who must submit a COI disclosure will receive an email notification reminding them of this requirement and providing further details. The notification is typically sent out on August 16th or shortly thereafter.
The U.S. Public Health Service (PHS), the National Science Foundation (NSF), and other organizations that sponsor research require their grantees to follow strict conflict of interest regulations. UNC General Administration also expects all members of the University community to avoid conflicts of interest and conflicts of commitment by ensuring that such conflicts are disclosed in one’s annual COI disclosure, reviewed, and appropriately managed, if necessary. Having a COI disclosure on record ensures that you are in compliance with these federal, state, and University regulations. Failure to comply can carry severe consequences, up to and including the suspension of the University’s entire portfolio of grants from a specific agency.
Disclosure of a conflict of interest DOES NOT prevent you from maintaining the disclosed circumstance. Instead, disclosure endeavors to manage the circumstance to avoid impairing your objectivity while performing your University duties and participating in research projects at NC State.
The University relies on you to file your annual COI disclosure and keep it up to date so that it continues to meet its institutional obligations to UNC GA and the agencies that fund University research. Submitting a COI disclosure demonstrates your commitment to keep your research objective and free of bias, which in turn preserves the public’s trust in the University’s research findings and safeguards support and funding for future research.
For more information, you may wish to take the “COI and NOI Overview, Disclosures, and Roles” module. You may find a link to that module on the Online Education Modules page of the SPARCS website.
Please visit the COI System Help page for detailed instructions about how to fill out and submit a COI disclosure.
The online disclosure form will provide guidance about what kinds of circumstances you need to disclose. However, in general, you MUST disclose:
- Any relationship you have with a third party that does business (such as sponsoring research or providing goods and services) with the University.
- Any relationship with a third party in which you hold a Significant Financial Interest.
- Any External Professional Activity for Pay (EPAP) in which you receive $10,000 or more in remuneration of any kind (Salary, etc.).
- Any intellectual property (Patents, trademarks, licensing agreements, etc.) contractually obligated to you or the University in which you are the author or owner.
- Any textbooks or other course materials for sale that you have authored or co-authored which you are also REQUIRING of students enrolled in coursework under your direction.
Please note again that the above list is not exhaustive. There are numerous other circumstances which the COI system will guide you to consider.
Please see the “What is a Significant Financial Interest (SFI)?” page for a full explanation of what constitutes an SFI.
Use the “Other Potential Conflicts of Interest” fields found in Section 4 of the COI disclosure form to disclose financial (and other) interests you may have that are not otherwise covered in the first three sections of the form, and that an external observer could believe may compromise your objectivity as a University employee. If you are unsure, consult with your associate dean for research or department head.
To learn more about management plans and when they are necessary, please see the Management Plan Guidance page. You may also wish to take the “COI Management Plan Overview” module. A link to that module may be found in the Online Education Modules page of the SPARCS website.
In brief, a management plan is a document that outlines and implements safeguard measures to reduce, mitigate, or eliminate an actual, potential, or perceived conflict of interest held by an employee. It details the actions and measures you and your department head and/or associate dean for research will undertake to ensure your objectivity is maintained while performing research and other duties at NC State.
Whenever relevant circumstances change regarding your external financial interests that are subject to the COI policy, log in to the COI system and select the option to “Create or Edit My Disclosure.” You will be given the option to create an entirely new disclosure or copy all of the information from your most recently submitted COI disclosure so that you can review and edit the form as needed and submit the updated disclosure for review and approval.
For more instructions about how to submit a COI disclosure, please see the COI System Help page.
No. Until you have submitted a COI disclosure for the most CURRENT disclosure period, and it has been approved, if necessary, you may NOT submit any proposals OR engage in External Professional Activities for Pay (EPAP).
Note: Disclosure periods run from August 16th to August 15th of each year. The current 2017-2018 disclosure period began on August 16, 2017, and will end on August 15, 2018.
COI disclosures are only valid for and count towards the disclosure period in which they were filed. The COI disclosure period at NC State begins on August 16th and ends on August 15th each year. In other words, the COI disclosure form expires on August 15th of each year and must be updated and submitted annually.
For a more detailed explanation of the COI disclosure year dates and how they affect the validity of COI disclosures, please see the Timing of the COI Disclosure Year at NC State page.
The COI system is an online form that eliminates the need to fill out and submit paper documentation. Once the online form is submitted, the COI system will record it and, if applicable, electronically route it to the appropriate department head, director, dean, or vice chancellor for review and approval.
If the employee does not have any circumstances to disclose, the approver is only notified that the form has been completed.
If you receive an error message stating that the COI system does not recognize your Unity ID and password, double-check that you have input your ID and password accurately and try again. If you still receive the error message, or have other questions regarding how to use the COI system, please visit the COI System Help page. You may also email email@example.com, call the SPARCS help desk at (919) 515-4267, or submit a help request online.
If you have forgotten your Unity ID and/or password, contact the SPARCS help desk at (919) 515-4357.
Your COI information is considered part of your personnel record. Access to the information contained therein is limited to personnel who need to review and approve your disclosure and to ensure that any resulting management plan is followed. This includes, but is not limited to, your department head, the director and/or associate dean for research in your college, your dean, your college research office, and staff in the office of Sponsored Programs and Regulatory Compliance Services. Others who may access your COI from time to time include the Office of Technology Commercialization and New Ventures, Vice Chancellor for Research and Innovation, and staff in the General Counsel’s office.