Revised: 2/5/2025
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All individuals with the designation of faculty, or other academic appointment, are required to 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.
Generally speaking, no. However, anyone listed as Key Personnel on any funded research must complete a disclosure. This could include staff, students, subcontractors, post docs, and fellows.
All Significant Financial Interests must be disclosed, regardless of value or amount, which could appear to affect the design, conduct, or reporting of your research,
OR
your performance of Institutional Responsibilities.
Significant Financial Interests include but are not limited to:
- Salary from employment or other payments for services such as:
- Consulting fees
- Data safety monitoring boards
- Scientific advisory boards
- Editorial compensation
- Guest Speaking
- Speaker’s Bureau
- Board of Directors compensation
- Royalties from the University of Chicago or outside companies
- Gifts
- Equity in companies (stock, stock options, shares)
- Intellectual property rights (patents, patent applications, copyrights, licenses)
- Travel sponsored or reimbursed (airfare, meals, hotels, parking, cab fare)
If you are unsure if an interest should be disclosed, always err on the side of disclosure. If you have any questions, please contact coi@lists.uchicago.edu.
The following does not need to be disclosed:
- Income from seminars, lectures, teaching engagements, advisory or consulting roles
- sponsored by U.S. government, academic institutions and research institutes and medical
- facilities affiliated with U.S. government or academic institutions
- Investments from mutual funds, retirement funds, and blind trusts that you do not directly
- control
- University of Chicago salary
- Grants and contracts through URA, including salary support
- Non-professional volunteer work
- Commissioned artistic work
- Honoria and travel expenses for talks at United States colleges and universities
- Reviewing journal manuscripts, book manuscripts, or grant/contract proposals
- Acting in an editorial capacity for a professional journal
- Travel to The University of Chicago Francis and Rose Yuen campus in Hong Kong or The John W. Boyer Center in Paris
No, you may complete an assurance stating that your institution/organization is PHS compliant. You must inform the University of Chicago of your decision to do so at the time of proposal submission. If your institution/organization does not already have a PHS compliant policy, you will need to complete the University of Chicago URA Disclosure Form for Subrecipients.
Yes, The University has established a zero threshold for disclosure reporting both in dollar value and in percentage (%) of equity holding, meaning that if the financial interest could reasonably be perceived to directly and significantly affect the design, conduct or reporting of research OR Institutional Responsibilities, it must be reported even if its dollar value or percentage is de minimus.
You are required to complete an annual disclosure at the beginning of the academic year (July 1). You are then required to update or modify your disclosure throughout the academic year as your financial interests change. Any changes must be reported within 30 days.
The reporting year opens on July 1 and closes at 5:00 pm on June 30.
In July, we ask that you report all activities you know you will have for the upcoming academic year. You are then required to reopen and update your disclosure throughout the academic year as new activities occur that were not reported in July. The disclosure will remain open for editing up until 5:00 pm on June 30.
Any changes to your disclosure, including additions, must be reported within 30 days.
You are required to report all activities that will occur during the current reporting period. Per federal policy, you are required to update your disclosure within 30 days of anything new. The deadline to report all activities for the academic year is 5:00 pm on June 30.
Yes, a comprehensive list can be found on our PHS Agencies and Sponsors Following PHS Regulations webpage.
Yes, all outside commercial activities need to be reported. You must report Equity, your title with the start-up company, and all intellectual property licensed to the start-up company.
All faculty and academic appointees are required to complete the disclosure. If you have no conflicts, you will indicate this on the form.
The Conflict of Interest policy requires all individuals with the designation of faculty, or other academic appointment, file annually a Conflict of interest-Conflict of Commitment Disclosure. 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.
Yes. Because faculty and academic appointees are professionals, weekends and other time outside customary business hours are not exempted from the counting, prior approval, disclosure, and reporting requirements.
Pursuant to revised federal regulations on conflict of interest and institutional policy, income received from publishing or authoring must be disclosed.
Book royalties will be disclosed as Intellectual Property Rights. Please state in the comments if this book is a required text for any of your courses.
Yes, conflicts do not have to be related to research to be reportable.
The term “University responsibilities” refers to any professional responsibilities that you undertake on behalf of the University, which may include, for example, research, research consultation, teaching, professional practice, Institutional committee memberships, and service on panels such as Institutional Review Boards or Purchasing Committees. Professional expertise refers to anything in your area of expertise with the caveat that it shouldn’t be applied too narrowly. This does not mean that this term broadly captures the entirety of one’s field, such as engineering, biology or political science. When evaluating what is related, instead consider aligning your analysis with the appropriate sub-field, such as electrical engineering, molecular biology or political theory.
Yes, the interests of a spouse are reportable if they meet the reporting criteria and threshold.
Yes, expert legal testimony is reportable.
The University of Chicago reports on the current academic year. You are required to disclose any activities and payments within 30 days. Please keep track of all activities and payments and report them as they occur.
All emeritus faculty and academic appointees that participate in research are required to complete the annual disclosure. The emeritus faculty or academic appointee can discontinue completing the annual disclosure once they have recused themselves from all research activities.
Failure to submit the disclosure is in violation of the University’s COI and COC policies. Failure to submit the disclosure in a timely manner may delay or prevent the submission of research grant proposals, receipt and disbursement of research award funds, and inclusion on human subjects research protocols.
You are only required to disclose stock that you personally chose to invest in. Any stock holdings chosen for you on your behalf by a third party do not need to be disclosed.
For individuals who receive PHS funding or funding from any of the aforementioned organizations, any externally supported travel must be reported within 30 days. This disclosure requirement does not apply to travel that is reimbursed or sponsored by the following:
• A U.S. federal, state, or local government agency.
• A U.S. Institution of higher education as defined at 20 U.S.C. 1001(a)
• A U.S. academic teaching hospital, medical center or research institute that is affiliated with a U.S. Institution of higher education
When reporting your sponsored industry travel, you need to report the following information:
• Dates and/or Duration of Travel
• Amount (e.g. hotel, travel, meals, honorarium, etc., if known)
• Destination
• Purpose of the trip
• Who funded the trip
Sponsored Travel is meals, hotels, airfare, transportation, and parking paid for on your behalf or reimbursed to you.
Yes, travel expenses paid for on your behalf or reimbursed by an outside entity must be reported.
Disclosures will be submitted at aura.uchicago.edu within the COI-COC module.
Yes, you will be able to access your COI Disclosure at any time by logging into AURA COI-COC at aura.uchicago.edu. A link to your current disclosure will available on your Dashboard under “My Current Disclosure”. If a link is not available, please contact coi@lists.uchicago.edu for assistance.
Yes, the disclosure will be available to update throughout the year up until 5:00 pm on June 30. There is no limit to the number of times you can update your disclosure throughout the year.
Yes, you may return to complete it at a later date. Your information will be saved.
If you know the expected amount you will receive for the entire academic year, you may enter today’s date as the Date of Transaction and enter the total amount in the Amount field. If you do not know the expected amount, you will enter your payments when you complete the activity. You are required to reopen and update your disclosure within 30 days of any new activity (not necessarily when you receive payment). In the comment section, you should state the specifics.
You may enter the first of the month. For example, June 1, 20XX.
You should select the most general entry.
You will select “No” in the blue box at the bottom of the page titled “What to Disclose”. Then click Continue.
Please write to coi@lists.uchicago.edu for assistance.
You will go to aura.uchicago.edu and click on the COI-COC module. Once logged into Two Factor / Duo Mobile, click on the link to your current disclosure under “My Current Disclosure”. On the left hand side of the screen, click the button titled “Edit My Disclosure”. You can simply type “updating” when prompted to explain why you are updating your disclosure. On the left hand side of the screen, click the Edit Disclosure dropdown and choose Introduction. Follow the prompts.
Click on the Validate button in the gray menu on the left hand side of the screen. It will have a green check mark next to it. You will then see your Error/Warning Messages. You can click on the links to be taken directly to the missing information. Please reach out to coi@lists.uchicago.edu for additional assistance.
(For screenshot, review PDF version of FAQ)
The Conflict of Commitment Policy defines one day on a case-by-case basis, using common sense and customary practice. Please contact coi@lists.uchicago.edu for additional clarification.
The form is asking you to enter how much time you spent working on that specific activity for that company. For instance, for Guest Speaking you will calculate how much time you spent preparing and delivering the speech.
You will no longer be able to edit the closed disclosure. Instead, please send an email to coi@lists.uchicago.edu with details on the information you forgot to add. We will note this on your behalf.
Please write to us at coi@lists.uchicago.edu requesting verification.
The Conflict of Interest Office reviews your disclosure.
The COI Office keeps all disclosure information confidential. When potential conflicts are identified that require management, only those financial interests relevant to or intersecting with research or other institutional responsibilities are shared with the IRB, Section Chief, Chair and Dean of that faculty member, if applicable. All information pertaining to Outside Activities are shared with a faculty member’s Chair and/or Dean, or their designee.
Yes, the information entered on your COI Disclosure is privileged and confidential.
Please forward the request to coi@lists.uchicago.edu. The COI Office will provide the necessary verification.
You will report the activity in June when the event occurs. You may enter an estimation of what you expect to be paid. Please contact coi@lists.uchicago.edu for additional guidance.
Meals will be disclosed as Sponsored Travel.
A COI Management Plan is implemented by the University when a conflict of interest is identified. A Management Plan is necessary to maintain the integrity of research, ensure against the introduction of bias, and protect the faculty member and University from undue influence from their financial interests. The purpose of this document is to mitigate risks that a conflict might cause in relation to a faculty member’s research or other institutional responsibilities. It identifies and describes the financial interest(s) creating the conflict, the limitations for faculty member’s role in research or other institutional responsibilities impacted by the conflict, and the requirements around disclosure of such financial interests to relevant parties (e.g., co-investigators, lab staff, students, postdocs, human subjects, patients and in oral presentations and written publications). If necessary, the document will also include a plan for independent oversight by a non-conflicted third party(ies).
Yes, the presence of a COI Management Plan will not impact your ability to submit proposals or receive awards or contracts to fund research. However, any limitations and requirements outlined in the Management Plan may impact your ability to participate in certain aspects of the research.
Your COI Management Plan will be viewed by your Department Chair or Dean. Any specific faculty member(s) or administrative staff providing oversight for the management plan will view it. If the management plan is related to human subjects research, the IRB view it. Lastly, management plans for medical center faculty will be viewed by their office of corporate compliance.
No, the COI office asks all individuals who report a relationship with any entity outside of the United States the same questions in the same manner.
Yes, this is a federal policy that the University of Chicago is required to enforce. The University also requires disclosure for professional purposes, as travel could be perceived as related to University related duties or sponsored research.
A foreign talent recruitment program is any program, position, or activity that includes compensation in the form of cash, in-kind compensation, including research funding, promised future compensation, complimentary foreign travel, things of non de minimis value, honorific titles, career advancement opportunities, or other types of remuneration or consideration directly provided by a foreign country at any level (national, provincial, or local) or their designee, or an entity based in, funded by, or affiliated with a foreign country, whether or not directly sponsored by the foreign country, to an individual, whether directly or indirectly stated in the arrangement, contract, or other documentation at issue.
A malign foreign talent recruitment program is:
(A) any program, position, or activity that includes compensation in the form of cash, in-kind compensation, including research funding, promised future compensation, complimentary foreign travel, things of non de minimis value, honorific titles, career advancement opportunities, or other types of remuneration or consideration directly provided by a foreign country at any level (national, provincial, or local) or their designee, or an entity based in, funded by, or affiliated with a foreign country, whether or not directly sponsored by the foreign country, to the targeted individual, whether directly or indirectly stated in the arrangement, contract, or other documentation at issue, in exchange for the individual—
(i) engaging in the unauthorized transfer of intellectual property, materials, data products, or other nonpublic information owned by a United States entity or developed with a Federal research and development award to the government of a foreign country or an entity based in, funded by, or affiliated with a foreign country regardless of whether that government or entity provided support for the development of the intellectual property, materials, or data products;
(ii) being required to recruit trainees or researchers to enroll in such program, position, or activity;
(iii) establishing a laboratory or company, accepting a faculty position, or undertaking any other employment or appointment in a foreign country or with an entity based in, funded by, or affiliated with a foreign country if such activities are in violation of the standard terms and conditions of a Federal research and development award;
(iv) being unable to terminate the foreign talent recruitment program contract or agreement except in extraordinary circumstances;
(v) through funding or effort related to the foreign talent recruitment program, being limited in the capacity to carry out a research and development award or required to engage in work that would result in substantial overlap or duplication with a Federal research and development award;
(vi) being required to apply for and successfully receive funding from the sponsoring foreign government's funding agencies with the sponsoring foreign organization as the recipient;
(vii) being required to omit acknowledgment of the recipient institution with which the individual is affiliated, or the Federal research agency sponsoring the research and development award, contrary to the institutional policies or standard terms and conditions of the Federal research and development award;
(viii) being required to not disclose to the Federal research agency or employing institution the participation of such individual in such program, position, or activity; or
(ix) having a conflict of interest or conflict of commitment contrary to the standard terms and conditions of the Federal research and development award; and
(B) a program that is sponsored by—
(i) a foreign country of concern or an entity based in a foreign country of concern, whether or not directly sponsored by the foreign country of concern;
(ii) an academic institution on the list developed under section 1286(c)(8) of the John S. McCain National Defense Authorization Act for Fiscal Year 2019 (10 U.S.C. 4001 note; Public Law 115-232); or
(iii) a foreign talent recruitment program on the list developed under section 1286(c)(9) of the John S. McCain National Defense Authorization Act for Fiscal Year 2019 (10 U.S.C. 4001 note; Public Law 115-232).
Please email any concerns you have about any of your current or possible future foreign relationships to coi@lists.uchicago.edu
You may send an email to coi@lists.uchicago.edu with the investigator’s name and CNet ID requesting verification of submission.
Yes, send an email to coi@lists.uchicago.edu with your units/departments anytime after August 1 and up until June 30.
The COI Acknowledgment Letter is issued to all those who submit a disclosure to acknowledge review by the University, and to provide guidance and reminders about what is required when engaging in research or other institutional activities with entities with which you also hold financial interests. The general guidance provided may be modified in the context of specific financial disclosures and specific projects.