FAQ's for Conflict of Interest in Research
What is a conflict of interest?
A conflict of interest in research refers to situations in which significant financial interests or other personal considerations may compromise or could appear to compromise a researcher's professional judgment or integrity.
Who is required to submit a COI disclosure?
- All SLU faculty, staff, students and other trainees (regardless of pay) listed on an application and/or award for external research funding (includes Adjunct and/or Emeritus faculty);
- All listed Non-SLU senior/key personnel (regardless of pay) listed on an application and/or award for external research funding (if listed as senior/key personnel, may include Co-Investigators, consultants, and collaborators); and
- All other Non-SLU individuals responsible for the design, conduct, or reporting of research (if a Non-SLU individual is not identified as senior/key personnel, then the Principal Investigator must determine whether the Non-SLU individual is responsible for the design, conduct or reporting of research).
How do I know if I have a conflict of interest that needs to be disclosed?
All faculty, staff and students involved in research at Saint Louis University must submit a yearly Conflict of Interest Disclosure Form, whether or not an actual conflict of interest exists. If the office of Responsible Conduct of Research finds that your disclosure results in a potential conflict that needs to be managed, you will be contacted for further information and instruction.
How do I complete an annual Conflict of Interest Disclosure Form?
Please click here for instructions to submit your annual disclosure.
What are the key changes to the updated COI policy?
The key changes to institutional policy will include the following:
- Mandatory COI Training (Online COI training through CITI)
- Lower Threshold Disclosure
- Any combined income, compensation or stock in excess of $5,000 from a publicly-traded or non-publicly traded entity to the Investigator, including the Investigator's spouse and dependent children must be disclosed.
- Any amount of equity (stock, stock options, or other ownership interest) in a non-publicly traded entity (such as a start-up company) to the Investigator, including the Investigator's spouse and dependent children must be disclosed, regardless of value.
- Mandatory Travel Disclosure
- Any reimbursed or sponsored travel to the Investigator (including Investigator's spouse and/or dependent children) paid by an entity, including non-profit organizations, but excluding travel sponsored by or reimbursed by a government agency, a U.S. institution of higher education or a research institute affiliated with such, a medical center, or an academic teaching hospital must be disclosed within 30 days of each occurrence.
- Mandatory Disclosures Annually and Within 30 days of Discovery
- All persons involved in the design, conduct, or reporting of research are required to disclose all Significant Financial Interests (including travel) whether or not an actual Financial Conflict of Interest exists. Each investigator must submit an updated disclosure of Significant Financial Interests within 30 days of discovering or acquiring a new Significant Financial Interest.
If I have a conflict of interest, who decides what needs to be done?
If you are found to have a conflict of interest, your case will be reviewed by the Saint Louis University Conflict of Interest in Research Committee (COIRC). The COIRC meets monthly, and decides on appropriate management plans for individual cases. Appropriate management plans ensure the reduction, management, or elimination of the conflict.
I thought I've already taken CITI training. Do I have to do it again for COI?
CITI Conflict of Interest training is not CITI training for Human Subjects. You must take the CITI Conflict of Interest course if you are involved in research.
A lot of people think of CITI training as a course requirement for IRB. Saint Louis University uses CITI (Collaborative Institutional Training Initiative) for other courses as well, including training for animal subjects, Responsible Conduct of Research (RCR), Good Clinical Practice, and the latest Conflict of Interest course. If you are involved in the design, conduct, or reporting of research at SLU, you are required to first complete the Conflict of Interest course through CITI (www.citiprogram.org) and then complete the eCOI disclosure through eRS (https://ers.slu.edu/ers/logon.aspx).
Please note: It may take up to 48 hours for eRS to recognize that you have completed the CITI Conflict of Interest course.
For instructions on logging in to CITI and adding the Conflict of Interest course, please click here.
For more information on the Financial Conflict of Interest in Research policy and how to submit an eCOI disclosure, please click here.
I have Non-SLU researchers on my project. Do they comply with SLU's COI Policy?
In order to comply with federal regulations for conflict of interest, Saint Louis University's Office of Research Integrity must be in receipt of all Non-SLU disclosures prior to the submission of any external application for research funding and before award funds are disbursed.
- If a Non-SLU researcher will be part of a subaward agreement, then the subcontractor can provide written documentation indicating whether to use its own policy. Satisfactory documentation includes one of the following:
- A Letter of Intent to Establish a Consortium Agreement; or
- A signed letter from the authorized institutional official acknowledging (1) the institution has a COI policy that conforms to 45 CFR Part 94 and 42 CFR Part 50, Subpart F, (2) the listed collaborator is in compliance with such policy, and (3) the listed collaborator will be monitored for FCOI and reported to SLU within 30 days of participation on the research project of any identified FCOI(s) related to the award.
- If a Non-SLU researcher is involved on the project without the issuance of a subaward or a subcontractor elects to comply with SLU's COI policies and procedures, then a Non-SLU COI Disclosure Form is required prior to the submission of any external application for research funding and before award funds are disbursed. COI training will also be required at the time of award.
As documented COI disclosure is required prior to submission of an application, such disclosure should be initiated at least ten (10) working days in advance of the application deadline for Non-SLU senior/key personnel and other Non-SLU individuals involved in the design, conduct or reporting of research.
Who can I contact if I have a question?
If you have any additional questions about conflict of interest, please refer to the official Saint Louis University Conflict of Interest in Research policy, e-mail COI@slu.edu or call 977-7047.
Other Resources for Conflict of Interest in Research