Disclosure Review Process

Understanding disclosure reviews

Once you have submitted your disclosure, the financial interests you disclosed will be reviewed.

Types of Conflict of Interest Office review

Conflict of interest disclosures fall into two categories: those without outside interests and those with outside interests. If your COI disclosure reports no outside financial interests, the Kuali Conflict of Interest disclosure system immediately routes it into an “Up to Date” status and no COI Office review occurs, under normal circumstances.

If your COI disclosure reports outside financial interests, the form is immediately submitted to the COI Office staff and the status of “Submitted for Review” is displayed on your Kuali COI dashboard. The COI Office will review the disclosure to verify that it is complete. If additional information is required, you will receive an email.

Conflict of Interest Committee review

The COI Office will prepare a summary of each disclosure with outside interests and present it to the COI Committee for review. The COI Committee reviews the summary, the research activity of the disclosing individual, and other pertinent information to determine what action is necessary or what additional facts may be needed. Depending on the nature of the outside interest, the COI Committee may choose to manage, reduce, or eliminate the interest. The COI Committee also may determine that no action is necessary or request that a best practices memorandum be put into place.

Compliance review

A current and complete COI disclosure must be verified by various IU offices before any type of research or sponsored program activity may begin. Those offices include Contracts & Grants, Institutional Review Board, and the Office of Clinical Research. If you have not filed a current COI disclosure, you will be contacted to do so immediately. If you’ve filed a disclosure but it requires COI Committee review, the COI Office will expedite review at the next committee meeting. Failure to have a current disclosure on file or to provide additional information requested by the COI Office may result in a delay of study approval and/or release of research funds.