1. Disclosure of Conflicts of Interest and Commitment Why do we collect COI disclosures, and from whom do we collect? A note about our system of collection, and how it came to be that way Authority to collect disclosures is established by the Conflicts Policy, which charges University Conflicts Committee with implementation. Resource: Conflicts Policy http://www.policy.cornell.edu/Conflicts_Policy.cfm http://www.policy.cornell.edu/Conflicts_Policy.cfm

2. COI Expectations and Statistics The Trustees and Provost have established an expectation that 100 percent of academic personnel will file an annual disclosures. Of the 3,500 filers each year, approximately 15 percent file an in-depth part II form. Ten percent of those result in a “managed conflict.”

3. COI Process Roles and Responsibilities -Dean of Faculty & Vice Provost for Research -Deans and Designated Representatives -Department Chairs Resource: Administrative Procedures, COI http://www.oria.cornell.edu/COI/COI_AdminPr ocedures2005.pdf http://www.oria.cornell.edu/COI/COI_AdminPr ocedures2005.pdf

4. Collection of COI Data Part I form, available electronically and in paper Part II form, available only in paper Resource: Office of Research Integrity and Assurance (ORIA) website has electronic copies of Part I and Part II forms, http://www.oria.cornell.edu/coi/ http://www.oria.cornell.edu/coi/

5. Review of Part II Forms Review of Part II forms is different in each college, and ranges in complexity from one person reading form to full committee review Management of Part II forms is similarly specific to the colleges Resources: -Guidance for Department Chairs -Attachment A of the Cornell Conflicts Policy

6. Reporting of COI Data Designated Representatives in the Colleges report to Vice Provost Richardson by mid-June. Two status reports are posted to Sponsored Program Services on July 1. Report 1: Status with regard to the policy: list of personnel and whether they are in compliance or not. Report 2: Status of Part II filers: includes list of personnel with managed conflicts and the name of the manager of the conflict.

7. What happens when someone is not in compliance with COI policy? SPS will neither submit sponsored project proposals nor accept funding awards for individuals who have not filed an annual disclosure statement. Just-in-time filing of COI disclosures is discouraged, but is a solution when a proposal needs to go out the door. Remember, however, that the filing must be reviewed and recorded before SPS can move forward.

8. Impact of New Compliance Office on COI Process The Office of Research Integrity and Assurance (ORIA) has been charged with research compliance assurance. The office is directed by Dr. Ray Stinson. Additional staff include an associate director and staff for the compliance committees, including human subjects, animal research, and biosafety. ORIA will be responsible for the 2006 collection of COI disclosures. As the COI process moves to ORIA, it is likely that the system of collection of annual disclosures of conflicts of interest and conflicts of commitment will change. Questions?

9. Contact Information Lesley Yorke Office of the Vice Provost for Research 222 Day Hall; 4-4906 LAB14@cornell.edu