Overview of the COI Disclosure Process
At Proposal Stage
Prior to submitting proposals in Coeus for internal or external funding, the Investigators identified in the proposal must complete PI certification, which includes three COI Screening questions designed to help identify potential conflicts of Interest between the project and an investigator’s Significant Financial Interests.
If a potential conflict is identified, the investigator is prompted to complete a full conflict of interest disclosure in the My COI module in Coeus Lite. This is to provide additional information regarding the relationship of the project to the Significant Financial Interest. The full disclosure must be certified/submitted prior to routing the proposal for Department, Lab or Center Head approval.
- Depending on sponsor, if no conflict is identified at proposal stage an investigator may be required to complete a full conflict of interest disclosure in the My COI module in Coeus Lite at award stage
- If proposal is to a PHS sponsor please see the updated Sponsored Travel reporting requirements
At Award Stage
Prior to any resultant award’s activation the full conflict of interest disclosure must be reviewed and approved by the COI Officer. Per note above, depending on sponsor, if no conflict was identified at proposal stage an Investigator may be required to complete a full conflict of interest disclosure in the My COI module in Coeus Lite before the award is activated. If a disclosure is made at this time, it must be reviewed and approved by the COI Officer prior to award activation.
The ‘Rolling’ Disclosure Process
To make the COI disclosure process more efficient for Investigators and to better help MIT meet reporting requirements we are eliminating the summer annual disclosure process and moving to a ‘rolling’ cycle that treats any updates to your disclosure as the equivalent of an annual update to your COI disclosure. View sample award and proposal disclosure timelines.
Each of the following events will trigger a COI disclosure revision and will reset the 12-month expiration date:
- When you add or revise an SFI – (within 30 days of acquiring the new financial interest (PHS investigators only), 90 days for all others); or
- At time of award – if you didn’t complete a COI disclosure at proposal time, or
- Annually – if neither of the above occurs in a 12-month period. Investigators will receive an e-mail notification at least 2 months prior to the expiration date of their disclosure.
Travel (PHS sponsored Investigators only)
PHS Investigators must disclose Sponsored Travel paid on his/her behalf (either directly or through reimbursement) within 30 days of completion of the travel or being reimbursed, at the following times:
- at the time of submission of a proposal to PHS, looking back over the previous 12 months;
- thereafter, within 30 days following reimbursement or within 30 days following the completion of a trip, if the PHS Investigator has an active award or pending proposal with a PHS agency.
An Investigator need not disclose Sponsored Travel paid for or reimbursed by:
- MIT (e.g. paid from MIT funds or from sponsored awards funds managed at MIT)
- U.S. Federal, state or local governmental agencies
- U.S. Institutes of higher education
- U.S. Research institutions affiliated with institutions of higher education
- U.S. Academic teaching hospitals and medical centers
For all Kuali Coeus systems related help questions, please e-mail email@example.com
For all MIT COI policy related help questions, please e-mail firstname.lastname@example.org