Will investigators need to complete training before a new award or change to an existing NIH award can be set up in Coeus and SAP?
Yes, the new CITI training on COI will need to be completed.
If individuals are named in an NIH Notice of Grant Award when it is initially received, but not named in the NOAs for following incremental years, are they still Key Persons?
Yes. They must still be treated as named key persons and prior approval from NIH is required before removing them as Key Persons on the award.
Does all foreign travel need to be disclosed?
All travel sponsored or reimbursed by a foreign organization must be disclosed, regardless of the type of organization sponsoring the travel. Foreign (and other) travel sponsored or reimbursed by any of the following need not be disclosed:
U.S. Federal, state or local governmental agencies
U.S. Institutes of higher education
U.S. Research institutes affiliated with Institutes of higher education
U.S. Academic teaching hospitals and medical centers
Is the CITI training required for every proposal?
No. Completing the training once will last for 4 years.
If the NOA simply says change in “Key Persons” needs approval, do you have to go to NIH for approval?
Only if the Key Person is actually named in the award would approval be required per NIH policy.
I generally pay for travel to professional meetings out of my own pocket, in order to maximize the funding available from each of my grants to pay students. Do I need to file travel disclosures for such trips?
The NIH travel disclosure policy does not include your own travel which you pay for yourself and for which you are not reimbursed. It is only reimbursed or sponsored travel that requires reporting.
For how long is the CITI COI training valid?
4 years. There will be reminder prompts sent to investigators/Key Persons when the expiration of their current training is approaching.
In the NIH Progress Report, does listing someone by name in the “all personnel report” mean that person has been identified as a key person and will be subject to the regulations regarding training and COI disclosure?
No. Only if you identify an individual specifically as a Key Person in a progress report or a proposal will they be subject to the regulation requirements.
Should/could Travel Disclosures be entered when the trip is booked, or only after completion of the trip?
You can log travel into the Coeus Travel Disclosure at the time of booking, and can then later update it if the trip is changed or canceled. If entering a trip in advance, when you get to the Certify page, Quit, do not certify. This will save all your entries to this point but will not submit it for review, leaving it available for future editing. Just be sure that the travel report is Certified and submitted within 30 days of completing the trip.
Is it correct that personnel cannot be charged to an award until their COI Training is completed?
If a new Key Person is added to an award, s/he cannot be charged to that award until the CITI COI training is completed. For new awards, renewals and changes to awards issued 8/24/2012 and after, no spending on the award can take place until all investigators and confirmed key persons have completed the training.
How should Subrecipient PIs/Consortium PI’s etc be entered in proposals?
They should be entered as Key Persons with the role “Subaward Investigator” in order for Coeus to handle them correctly and not require certification or COI (which should be handled at their own institution).
Who needs to complete an OPA form?
Administrative staff, Faculty, Other Academic staff and Research Staff. Support and Service staff do not need to fill them out. Please contact your department headquarters for more information.
If I have no Active SFIs in Step 2 why can’t I continue with my disclosure?
If you have no active SFIs in Step two but do not see the Continue With Disclosure Button please use the Return to Screening Questions button to review your answers there to see if any responses to screening questions need to be edited. If your screening answers determine that you have no conflicts, and you have no active Significant Financial Interests, you automatically skip past steps two and three and proceed directly to Step Four – Certify.
Does the aggregator need to exit proposal before the PI can go in to do the certification or COI disclosure?
No, because the link in the certification notification does not send the recipient to the KC Proposal but to a separate Certification Questionnaire. Completed certifications will update even if the aggregator has a lock on the KC Proposal. COI Disclosures are in Coeus Lite, not in the KC proposal.
I have been instructed to do a disclosure, however, the Master Disclosure (or Initial disclosure) button is inactive. What should I do?
At a certain point during the process of creating and submitting a disclosure for review, you may find buttons on the MY COI menu screen are inactive (grayed out). If you started a disclosure but exited before completing it you may be able to locate it using the Other Disclosures in Progress button under the Revise heading. A quick card with further information on Inactive buttons is available here.
How should Subrecipient PIs/Consortium PI’s etc be entered in proposals?
They should be entered as Key Persons with the role “Subaward Investigator” in order for Kuali Coeus to handle them correctly and not require certification or COI (which should be handled at their own institution).
How long will the COI training take? How onerous is it?
The CITI COI training should take about 45-60 minutes to complete. It may vary for individuals.
Will an aggregator be able to see that a PI has completed their certification?
Yes, if completed, you will see next to PI/co-I/Key Person’s name, "Certification Completed and Answered By ________ - mm/dd/yyyy hh:mm)"
On a Fellowship Application to NIH, we sometimes see a Co-sponsor in addition to the Sponsor listed in the Key/Persons. Should we dissuade fellowship applicants from including Co-Sponsors?
If the two sponsors have different areas of expertise, e.g. the Co-Sponsor works at a hospital while the Sponsor is MIT faculty, they should both be included. However, unless there is a clear addition to the field of expertise, these should generally be limited to the Sponsor. (Note; if the co-Sponsor is from another institution, they will need to go to IS&T to get a Kerberos account and MIT certificate in order to complete the proposal Certification and COI disclosure & Training)
If we are the sub on an NIH prime award and our PI determined some people are Key Persons, but the prime awardee does not include them, do we need to name them as Key Persons, have them complete Key Person certification and submit a proposal disclosure (if needed based on certification answers)?
Yes. If the MIT PI identified them as Key Persons for the MIT portion of the project, they should be included in the Key Persons on the proposal and the regulations/requirements apply.
If you are deleting a Key Person from an award in Kuali Coeus, do you have to go to NIH for approval?
Not if the person is not named in the award notice from NIH. You would, however, still need to include the change to key persons in the Progress Report with NIH.
Can the training be done remotely?
Yes. The training is web based with certificate access, and can be done on any computer on which the investigator/key person has a personal MIT certificate installed.
Do PI’s need to know the proposal number in order to access certification or COI?
The notification email link will bring them directly to the correct screen in Kuali Coeus for certification. At the end of the Certification questions, they will be prompted with a link to the COI site if a full COI is required. If they leave the COI module and have to reenter, they can go in again through “MyCOI” where they choose from a list. The PI would then need to know which one to choose.
Does travel disclosure apply to NIH Investigators only?
At this time the travel disclosure requirement applies to NIH and other PHS agency Investigators and Key Persons, plus Investigators with awards from Foundations that invoke the PHS COI policy. For a list of these foundations please see here.
Can an investigator do a new disclosure without having completed the training?
Yes. The training is on policy, some of which they would need to know in order to know what to disclose, but yes, the training and the COI disclosure are separate and are separately tracked.
Who can maintain key persons?
PI’s will automatically have access (with their MIT certificate) to maintain the Key Persons on their awards in Kuali Coeus My Awards. Upon entering My Awards (coeus.mit.edu), an Investigator will see a list of their awards.
In addition to the Principal Investigator, OSP can also assign the role of “key person maintainer” to a department administrator to maintain this information. This role will allow an administrator to edit the key person information for all awards in their unit.
To request this authorization, an Administrative Officer or Fiscal Officer must send a request to email@example.com. Please include the name and email address for each individual as well as the unit(s) for which they should have the role assigned.
We understand that there are situations where you may want to grant an administrator authorization for the awards of a single PI or group of PIs; Unfortunately, OSP was not able create that role for the initial implementation but will do so in the future if it becomes problematic.
In the information about travel reporting requirements, it lists an exemption for travel sponsored by a research institute. Does this include foreign research institutes?
Foreign universities and foreign research institutes affiliated with them are not included in the exemption and travel sponsored or reimbursed by them does require a travel disclosure.