University COI and COC Disclosure Obligations

Conflict of Interest and Conflict of Commitment Disclosure Obligations (University COI/COC Policy)

Faculty and other investigators must disclose significant financial interests received (including from foreign governments, universities, and institutions), per the University of Chicago’s Conflict Of Interest And Conflict Of Commitment Policy For Faculty And Other Academic Appointees. The definition of “significant financial interest” is set forth in the Policy, and includes “anything of monetary value that does or could reasonably be perceived to directly and significantly affect the design, conduct or reporting of funded research, or the performance of other Institutional Responsibilities, whether or not the value is readily ascertainable.” Examples include, but are not limited to, salary or other payments in connection with appointment or employment at another institution or consulting, royalties, equity interests, and intellectual property.  If you are unsure whether a particular interest or remuneration meets this definition, please contact Mallory Snyder, Director, Research Integrity ((773) 702-4857;

The Policy also sets forth additional requirements for PHS-funded investigators regarding reimbursed or sponsored travel related to their University responsibilities, as described in greater detail below under “Reimbursed and Sponsored Travel".

  1. It is the responsibility of each faculty member and other person covered by the Policy to comply with its terms. While those covered by the Policy must disclose certain financial interests and other arrangements to the University, sponsors may require additional disclosure to the University or to the sponsor directly. It is the responsibility of each faculty member and other person involved in research to understand and comply with any such additional disclosure obligations. 
  2. For U.S. Public Health Service (PHS)  investigators, training on PHS-specific financial conflicts of interest (FCOI) requirements is available here
  3. Disclosure is completed in the AURA COI system at the beginning of each fiscal year.  Disclosures should be updated throughout the year (i.e., within 30 days of any changes).