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

The University of Chicago's Revised Conflict of Interest 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 COI-COC 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 

*On July 1st, a new Conflict of Commitment (COC) Policy went into effect. We developed a separate, more streamlined COC policy that provides greater clarity on COC issues for academic appointees and emphasizes COC management at the academic unit-level. COC policy changes directly affecting faculty and OAA disclosure responsibilities and requirements are summarized as follows:

Time Limits and Management of Compensated Outside Professional Activities

  • Twelve-Month (4Q) Appointments. A full-time Academic Appointee on a Twelve-Month (4Q) Appointment normally may engage in Compensated Outside Professional Activities for up to 48 days during the period from July 1 to June 30.
  • Academic Year (3Q) Appointments. A full-time Academic Appointee on an Academic-Year (3Q) Appointment normally may engage in Compensated Outside Professional Activities for up to 39 days from the start of the Autumn Quarter through the end of the Spring Quarter (including the periods between quarters). There are no restrictions on the number of days of Compensated Outside Professional Activity for Academic Appointees on Academic Year (3Q) Appointments during the summer months, unless the Academic Appointee is receiving University compensation for the summer (or equivalent term). If an Academic Appointee on an Academic Year (3Q) Appointment is receiving University summer compensation, then the applicable limit on Compensated Outside Professional Activities is the equivalent of one day per week during the period in which compensation is received.

Categorization of Compensated Outside Professional Activities

  • Eliminates prior policy’s need for prior approval of most compensated outside activities.
  • Classifies compensated outside professional activities into 3 categories based on level of anticipated impact on institutional responsibilities:
    • Category I Activities: require prior approval of the Provost and, if permitted, are subject to a 39/48 day limit (for 3Q and 4Q appointees, respectively). No Category I activity may be undertaken without prior written approval by the Academic Appointee’s Administrative Official and the Vice Provost. Examples include compensated teaching outside the University, or accepting salaried employment outside the University
    • Category II Activities: do not require prior approval but must be reported annually and are subject to a 39/48 day limit (for 3Q and 4Q appointees, respectively) per academic year. Examples include consulting for industry and service on boards of directors
    • Category III Activities: do not require prior approval, do not need to be reported, and are not subject to 39/48 day limit. Examples include service on scholarly committees or panels, speaking at academic conferences, or accepting a commission for an artistic work or performance
    • Additional examples of activities in each category can be found in the COC policy document.


  • Uncompensated Outside Professional Activities are not subject to the 39/48 day limitation, but such endeavors nevertheless must not interfere with an Academic Appointee's Institutional Responsibilities.

Questions about COI or COC Policies or the Disclosure Process?


Mallory Snyder Okubanjo, Director of Conflict of Interest at or (773) 702-4857.

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