Rutgers University Investigator Conflict of Interest Policy 90.2.5 requires that PIs and all personnel working on research projects, regardless of source of funding or lack thereof, disclose financial information that may reasonably be perceived to influence their work. This policy is intended to promote objectivity in research with the reasonable expectation that the design, conduct, and reporting of the research will be free from bias resulting from Investigator financial conflicts of interest.
Please note that having something to disclose does not imply any wrong-doing or inappropriate activities. The emphasis is on disclosure of financial interests so that Rutgers can conform to federal financial disclosure rules and those of many granting entities.
Who Needs to Disclose
All University faculty, non-faculty employees, students (graduate and undergraduate, part-time or full-time) and other individuals who, in the course of their association with the University:
- apply for or receive funds for any research or training purpose, by grant or sub-grant, or by contract or subcontract, or by cooperative agreement, or are engaged in research (i.e.: are responsible for the design, conduct, or reporting of research; or (For example: an undergraduate student entering data must disclose because they are engaged in the conduct of the study, or administrative personnel must disclose, who have decision-making authority over the distribution of funds, whether research or discretionary)
- conduct unsponsored/unfunded research
Disclosing for Non-Rutgers Researchers
For projects involving contracts, subcontracts or collaborations with outside institutions or groups, Rutgers will take steps to ensure that any subrecipient Investigator complies with the Public Health Service, pursuant to 42 CFR Part 50, Subpart F by incorporating as part of a written agreement with the subrecipient terms that establish whether the financial conflicts of interest policy of the awardee Institution or that of the subrecipient will apply to the subrecipient's Investigators.
In the event the outside entity has no investigator conflict-of-interest policy, the written agreement referenced above shall specify time period(s) for the subrecipient to submit all Investigator disclosures of significant financial interests to Rutgers. The subrecipient will be required to:
- request a Rutgers NetID guest account from Rutgers OIT.
- complete the Rutgers Conflict of Interest Disclosure in Electronic Conflict of Interest (eCOI) system.
- comply with the Rutgers Conflict of Interest Policy 90.2.5.
***The FDP FCOI Institutional Clearinghouse provides a central location for educational institutions and other entities to document that they are in compliance with the PHS Financial Conflict of Interest (FCOI) rules and regulations. Note that not all institutions are registered on this website, you may need to contact them directly for more information about their CoI Program.
What You Need to Disclose
All investigators should disclose any “financial interest” or other personal involvement of the investigator, or his or her immediate family, that are related to the individual’s Institutional responsibilities.
Financial interest means anything of monetary value, whether or not the value is readily ascertainable. Interests include, but are not limited to: income; honoraria or other payment for services; equity such as stock, stock options or other ownership rights, employment; reimbursed travel or sponsored travel; and services, relationships or positions, even if uncompensated.
Excluded from the disclosure requirement are:
- Interests of any amount in publicly traded, diversified mutual funds, pension funds, or other institutional investment funds over which the faculty member does not exercise control); patents and copyrights; contracts, licensing and other agreements; royalties (including those royalties distributed by the University).
- Income from seminars, lectures, or teaching engagements, reimbursed travel or sponsored travel, and service on advisory or review panels sponsored by a federal, state, or local government agency, a domestic institution of higher education as defined at 20 U.S.C. 1001(a), a domestic academic teaching hospital, a domestic medical center, or a research institute that is affiliated with a domestic institution of higher education. Note that foreign institution income may not be excluded.
For more information on the type of interests to disclose, please review the Rutgers University Policy Policy 90.2.5 “Investigator Conflict of Interest”.
When Do You Disclose
- At Award Set-up: For a new award, a Research Certification must be created in the eCOI system once the award is received. If a disclosure has never been submitted before, the Investigator must submit a disclosure now. The award will not be processed for set-up until all study team members have certified in the eCOI system. A Research Certification does not need to be created for incoming awards that are not new.
- Annually: Disclosures must be updated at least annually. Investigators will only be notified to update their disclosure annually if no action has been taken within the last 12 months.
- Within 30 days of a new Significant Financial Interest (SFI): A revised COI disclosure must be made within thirty days of discovering or acquiring a new significant financial interest (e.g., through purchase, marriage, or inheritance).
- Example A: Dr. Smith submitted a COI disclosure on July 1, 2017. Dr. Smith submitted a proposal on October 5, 2017. No update to Dr. Smith’s COI disclosure was needed.
- Example B: On December 1, 2017, Dr. Smith receives an award letter. Dr. Smith’s administrator creates a Research Certification in the eCOI system. Dr. Smith and the identified study team members each log into the eCOI system and verify their disclosures are accurate.
- Example C: Dr. Smith got married and Dr. Smith’s spouse is the CEO for a pharmaceutical company. Dr. Smith must submit an updated disclosure within 30 days to include any financial interests held by Dr. Smith’s spouse.