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Conflict of Interest (COI) Disclosures

All key personnel are required to submit a COI disclosure when receiving external funding to ensure 911黑料爆料网 and its auxiliaries (UCorp) are in compliance with federal and state requirements.

About Conflict of Interest Disclosures

To better identify and mitigate all possible conflicts of interest (COI), 911黑料爆料网 and axillaries now require COI disclosures for ALL funded projects. 911黑料爆料网 is committed to upholding the highest ethical standards in research. By requiring COI disclosures for all investigators, we are able to proactively identify and mitigate any real or perceived conflicts that could compromise research objectivity, funding eligibility, or public trust. Having a transparent COI management program will further strengthen the credibility of our faculty-led research and ensures that external stakeholders, including funding agencies and the public, have confidence in the 911黑料爆料网’s research enterprise.

A COI Disclosure is needed prior to proposal submission, verified upon award, annually while funded, and ad hoc 30 days within a new financial interest identified and when new investigators join a funded project in accordance with the 911黑料爆料网 Conflict of Interest Policy.  Subrecipients must also follow policies that comply with the funding agency’s regulations. COI training will be required per sponsor requirements and the 911黑料爆料网 Conflict of Interest Policy for External Funding.

What requires COI review?

911黑料爆料网 requires Conflict of Interest (COI) disclosures for all funded projects, government and non-governmental via Cayuse. Disclosures are required before proposal submission, upon award, annually during award, and within 30 days of changes. All key personnel on a funded project must complete training and submit a disclosure via Cayuse Outside Interests.

More information on when COI review is required

Required COI training

Personnel on proposals to DOD, DOE, NASA, NIH, NSF, and USDA must complete COI training when completing their Outside Interests disclosure form via Cayuse. COI training is valid for 4 years and offered via CITI Program. For private funding that is reported via the 700U form, you will be assigned required state training directly from 911黑料爆料网 Human Resources.

Maintain your Disclosure

Disclosures will need to be maintained for life of an award which may include annual disclosures to confirm relationships. Any changes to your financial and non-financial relationships should be reported within 30 days.

COI Review Process

All COI disclosures will now be processed via.

Step 1: Start your Outside Interests disclosure

An OI disclosure form is created for Personnel listed in a Cayuse SP proposal or award when it is submitted to the Sponsored Programs Office (SPO). 

OR

You can create you our Research-Based Disclosure from your Profile in Cayuse.

Step 2: Indicate the Sponsor Type: Governmental or Non-Governmental

Who is funding your project?

Many funding opportunities are proposed by foundations, non-profits, or private businesses. However, some of these organizations are supported by funds from federal or state organizations. This “behind the scenes” funder is known as the Prime Sponsor. The Prime Sponsor is the organization which determines the reporting requirements below.

What are some examples so I can better understand?

Sponsor Prime Sponsor Disclosure Requirements
San Jose State University Foundation National Science Foundation Governmental
Coastal Conservation and Research CA Department of Fish and Wildlife Governmental
ARI CSU Chancellor's Office CSU Chancellor's Office Governmental
Big Sur Land Trust Big Sur Land Trust Non-Governmental
Community Foundation for Monterey County Community Foundation for Monterey County Non-Governmental

How do I know which Sponsor Type to check?

  1. The best way to know is to work with your SPO Analyst to confirm what organization is the Prime Sponsor.
  2. You can also confirm this within your Cayuse Sponsored Projects proposal or award record by looking for the Prime Sponsor and Prime Sponsor Type in the summary or within the form.

Why does selecting the right Sponsor Type matter?

Non-governmental sponsors will require that you complete the 700U form which is a State of California requirement per Fair Political Practices Commission Title 2, Division 6, Section 18755.

  • Here is a Quick Reference Guide for completing a disclosure for

Governmental sponsors (direct or pass-through) will require that you disclose significant financial interests (SFIs) which include any member of the Investigator’s immediate family, specifically, any dependent children, spouse or domestic partner. 

  • Here is a Quick Reference Guide for completing a disclosure for

Step 3: Complete Questions about Other Relationships

Answer questions about foreign relationships and non-financial relationships related to the funded project.

Step 4: Complete and Certify

Review your disclosure form for completeness and accuracy.  Certify your disclosure and keep an eye on the status. 

Step 5: Review Status and Resolution

Review Status

  1. Unsubmitted – Your disclosure is incomplete and has not been submitted for review.
  2. Under Review – Your disclosure has been assigned for review.
  3. Returned – More information is needed about a relationship and you must respond to the COI office.
  4. Disclosure Complete - Your disclosure requirement has been fulfilled.

Resolutions

  • No COI Determined – No relationships disclosed pose a direct conflict.
  • COI determined and managed – The COI will be in touch to discuss a management plan.
  • COI determined and unmanageable – The COI cannot be managed or you find the management plan disagreeable.

Need help?

Email us at coi@csumb.edu

Who must disclose?

Any personnel on a funded project who are responsible for the design, conduct or reporting of the research. This would include senior and key personnel and all others who contribute to the scientific development or execution and reporting of a project in a substantive, measurable way whether or not they request or receive salary or compensation.

When must disclosure be made?

Personnel must disclose any changes or new potential conflicts within thirty (30) days of acquiring or discovering them.

Non-governmental Sponsors – 700U State of California requirement

The State of California requires principal investigators to disclose financial interests with non-governmental entities from which funding is requested to ensure public employees are not personally benefitting at the expense of the public interest. Reference Fair Political Practices Commission  Title 2, Division 6, Section 18755.

Governmental sponsors - Awards received directly from the designated sponsors or as a pass-thru award

In compliance with federal regulations, investigators and anyone responsible for the design, conduct, and reporting of research are required to disclose significant financial interests (SFIs) that could be reasonably expected to bias the design, conduct, or reporting of the project. The disclosure requirement also applies to any member of the Investigator’s immediate family, specifically, any dependent children, spouse or domestic partner. 

NOTE: For State of California or Chancellor's Office funds, check "Governmental" in the Cayuse OI disclosure form. 

The following are SFIs which must be disclosed:

  • Any income or other payment for services related to your institutional responsibilities (e.g., research, research consultation, teaching, professional practice, expert witness, advisory board membership, etc.) received within the previous 12 months which exceeds $5,000, including services completed during Sabbatical or Difference of Pay.
  • Publicly traded equity owned or acquired within the previous 12 months in any Publicly Traded Entity, the value of which exceeds $5,000. This includes any stock, stock options, or other ownership interest.
  • Any payments received for any intellectual property rights and interests (e.g., patents, copyrights, trademarks, assigned or licensed to a party other than the Regents and excluding academic or scholarly works) within the previous 12 months which exceeds $5,000.
  • Travel reimbursement or payment by any entity within the past 12 months the value of which is equal to or exceeds $5,000. Payments from federal, state or local governments, U.S. institutions of higher education, or a research institute, academic medical center or hospital affiliated with U.S. institutions of higher education are excluded.

Foreign Support

911黑料爆料网 and auxiliaries requires disclosure of any foreign support and relationships to better identify possible conflicts of interest, real or reasonably perceived by others, which when disclosed to the University can further improve credibility and trust with sponsors, the research community, and within our local community. Investigators must disclose all foreign financial interests to identify any potential malign foreign influence concerns.

Project-based Interests

Investigators must disclose any other interests, including non-financial, related to institutional responsibilities and external funding that could present an actual or potential conflict of interest. 911黑料爆料网 and auxiliaries intend to avoid any real or apparent conflict of interest while performing project-based activities. It is up to 911黑料爆料网 and auxiliaries to evaluate the existence of any real or apparent conflicts of interest and resolve them accordingly. Conflicts of interest include activities where investigators use their positions for purposes that are, or give the appearance of being, motivated by a desire for private gain for themselves or others, such as those with whom they have family, business or other ties.

Identification of relationships that may be recognized as a perceived or actual conflict of interest can further improve credibility and trust with sponsors, the research community, and within our local community. The University recognizes disclosure as a key factor in protecting one's reputation and career from potentially embarrassing or harmful allegations of misconduct.

Get Support for Your COI Requirements

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Michelle Burgett-Moreno

Research Integrity and Compliance Officer