Conflict Of Interest-Conflict Of Commitment (COI-COC)

The University of Chicago's Conflict of Interest/Conflict of Commitment Policy requires that all individuals with the designation of faculty, or other academic appointment, file annually a Conflict of interest-Conflict of Commitment Disclosure. Furthermore, any individual that is engaged in the design, conduct or reporting of research, or is considered "key personnel" must comply with the policy. This is a University wide policy, and applies regardless of whether the faculty or academic is engaged in research, or receives external research funding, and regardless of whether they have a full time or part time appointment.

As of August 2012, The University's Conflict of Interest-Conflict of Commitment Disclosure process was revised to capture both the new federal requirements, as well as The University of Chicago and the University of Chicago Medical Center requirements.

Subrecipients will complete the URA COI Disclosure Form for Subrecipients if they do not have a PHS (Public Health Services) compliant policy on Conflict of Interest at their primary appointment institution.

In addition to completing a Conflict of Interest Disclosure form, researchers who are applying for and/or funded by a PHS institution, must show evidence of completing conflict of interest training every 4 years. This must be completed prior to grant submission. Using CNet ID, researchers should log into CITI (Collaborative Institutional Training Initiative, and complete the Conflict of Interest course.

This course is made up with three modules:

  • CITI Conflict of Interest Introduction
  • Financial Conflicts of Interest: Overview, Investigator Responsibilities and COI Rules
  • Institutional Responsibilities as They Affect Investigators

When the training expires in 4 years, the Researcher must complete the CITI COI Refresher Course.

CITI Program Guides:

Note: To facilitate compliance with applicable law, reporting obligations and institutional policies, information disclosed may be shared with officials and administrators responsible for conflict of interest-conflict of commitment oversight at both The University of Chicago and The University of Chicago Medical Center 

Questions about COI Policy or the Disclosure Process?


Mallory Snyder, Director of Research Integrity at or (773) 702-4857.

Questions about AURA-COI or COI CITI Training:  please contact