Who is required to complete a COI?
- Every EPA employee
- Post docs
- Adjunct and Emeritus faculty on appointment
- Anyone paid in whole or in part from a sponsored project (5‐account) – including, but not limited to SPA employees and Graduate Assistantships
When do I complete the COI?
Annually, all faculty members, EPA and covered SPA employees are required to submit a new COI disclosure. The COI disclosure period is August 16th through August 15th of each year, so a new disclosure is required. Covered employees are asked to complete the COI each year by October 1st of each year.
In addition to the annual COI disclosure, all covered employees must update their disclosure as circumstances change. A message reminding covered employees to contemplate possible conflicts is sent in January of each year, but it is the employee’s responsibility to update his/her disclosure as soon as reasonably possible.
How does the online COI system work?
The NC State University Conflict of Interest system is an on-line form that eliminates the need to complete and submit paper documents. Once the on-line form is complete the COI system will electronically route the disclosure to the cognizant department head, director, dean or vice chancellor for review and approval. If the employee’s circumstances are such that there is nothing to disclose, the cognizant approver is only notified that the form has been completed.
How do I complete my COI?
The COI annual disclosure is completed, submitted and routed for approvals online. You may access the COI system via our secure server. You must authenticate to the system using your Unity ID and password. If you have not yet submitted a disclosure you will select the link entitled “Create New Disclosure” and the system will guide you to the initial questions. When asked questions about “you”, remember that this includes you, a spouse/partner or child living in your household. If an answer is yes, you will be asked to provide more details via additional questions that will appear based on your answers. One component of the COI online system is the development of a management plan that is incorporated into the additional questions asked if a disclosure is made. Once you have completed the form you are asked to certify your responses.
What is a Management Plan?
If circumstances are such that an external financial relationship exists, you may be required to file a management plan to ensure optimal objectivity in carrying out your NC State duties. A management plan is derived from and included in your COI disclosure. The plan should detail the actions and safeguards that you and your department head and/or associate dean for research will undertake to ensure your objectivity is maintained.
What financial interests need to be disclosed?
The significant financial interests that must be disclosed include:
- Income of $10,000 or more from an external entity that does business with the University, sponsors projects, or hires students or other employees for which you are responsible, including:
- Salary, consulting fees, honoraria, royalty payments dividends, interest income, or the proceeds from the sale of equity you may own.
- Investments in an entity that does business with the University, sponsors projects, or hires students or other employees for which you are responsible, including:
- Stocks, bonds, or other equity instruments either $10,000 market value or 5% equity interest, regardless of market value.
- Positions with an entity that does business with the University, sponsors projects, or hires students or other employees for which you are responsible, including:
- Founder, partner, director, manager, officer, trustee, employee, or any other position of management with the entity.
- Intellectual property / Textbooks:
- Textbooks and other classroom materials you author, make for sale, and that are required for students in courses where you are the instructor of record.
- Intellectual property (IP) you created and that is licensed by the university.
What should I do if I can’t login to the COI system?
Call the specialized help desk (515-4267) for assistance.
If you have forgotten your unity ID or password, you will need to contact the main help desk at 515-4357.
How will I be notified when I need to submit my annual disclosure?
Annually all covered employees will receive an email notification reminding you of this requirement. It typically is sent out on August 16 or shortly thereafter. The COI disclosure form expires on August 15 of each year and must be updated and submitted annually.
Who has access to the information I submit in the COI system?
Your COI information is considered part of your personnel record. Access to COI information is limited to personnel with a need to know, in order 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, director, 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 Transfer, Vice Chancellor for Research and Innovation, and staff in the General Counsel’s office.
How do I update my COI during the year as circumstances change?
Whenever relevant circumstances change regarding your external financial interests that are subject to the COI policy, simply log into the COI system and select the option entitled “Create or Edit My Disclosure.” You will be given the option to create an entirely new disclosure or copy your former COI disclosure so that you can review/edit the form as needed and submit the updated disclosure for review and approval.
What if I have a financial interest that doesn’t quite fit the questions in the form, yet I feel should be reported?
Section 4 of the COI disclosure form is entitled “Other Potential Conflicts of Interest”. Use the Other Potential Conflicts of Interest fields to disclose financial interests not otherwise covered in the first three sections of the COI form and that a reasonable 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.