More Information
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KSU has a uniform policy for financial conflicts of interest in research.
Reporting requirements vary by research sponsor, but our annual disclosure requirements are the same for all researchers, to ensure that we comply with all potential sponsor’s regulations.
Please note that you still need to report outside activities through the portal on
OwlExpress.
The FCOI policy for research only fulfills the reporting requirements of research sponsors and will not communicate
any outside activities to your Chair or Dean.
It is expected that investigators update their disclosures annually. You are also
required to update your disclosure within 30 days of acquiring a new reportable financial
interest.
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As part of our conflict of interest policy, we require that investigators on a research
team with outside support and a sponsor COI reporting requirement complete training.
Our training is available through CITI and is valid for 4 years. Please see the instruction sheet to add the COI course to your CITI profile. See the full list of CITI training available via KSU. |
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All investigators must disclose their significant financial interests as defined in
the policy at least annually. Please log in to the Cayuse Research Suite to complete your annual disclosure.
Please note that this is not the same server that is used for IRB submissions or for
proposal administration. Instructions and a walkthrough of the disclosure process are provided. You will file your disclosures from your Profile page in Cayuse.
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All faculty (including part-time and limited-term) are granted access to Cayuse automatically, via NetID and password.
Staff and students who receive “Forbidden” or similar errors when trying to log in will need to request Cayuse access. Fill out this form and enter “COI” in the Research Group Head field. You will receive an email confirmation once your profile has been created.
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Most investigators should file an “Annual Disclosure.”
The National Science Foundation currently requires grant recipients to file specific
COI disclosures for each funded project. Please log in to the Cayuse Research Suite and complete a “Research-based Disclosure” if you are applying for/have received NSF funding or are otherwise requested to do so by Sponsored Programs.
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Verification and Reminders
Each January, federally funded investigators will be reminded to update their disclosures for the calendar year. Please remember that all investigators on the project also need to disclose any significant financial interests as required by federal research sponsors (see “Who needs to file an FCOI Disclosure?” below). In July, there will be a second check of disclosure and training status to ensure that all new awards are up to date. Appropriate notifications to College administration and consequences will follow continued non-compliance. Read the reminder process details. |
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Please contact researchcomp@kennesaw.edu with any questions about COIs or disclosures, and service@kennesaw.edu with any technical issues.
Cayuse works best with Chrome or Firefox.
Cayuse has a robust support website that is free (registration required) with information and walkthroughs of different tasks. These are also accessible through the help icon (Orange question mark) at the bottom right when you are logged in to Cayuse.
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Who needs to file an FCOI Disclosure?
The Public Health Service (i.e., NIH) regulations, and the KSU FCOI policy, indicate that anyone who is an Investigator on a project needs to receive training and file a COI disclosure. An Investigator is the project director or principal investigator and any other person, regardless of title or position, who is responsible for the design, conduct, or reporting of research, which may include, for example, collaborators or consultants. Investigator includes, but is not limited to, the Principal Investigator, project director, co-principal investigator, and may also include other Senior/Key Personnel, a postdoctoral fellow, graduate student, trainee, staff member,
collaborator, or consultant, depending on the person’s role in the research.
The primary factors to be used in determining who is an Investigator are the significance
of the tasks assigned to the individual regarding the design, conduct, and reporting
of the research and the degree of independence that individual may have in performing
such research-related tasks. The Public Health Service (PHS) Financial Conflict of Interest (FCOI) regulation applies to all individuals defined as project Investigators. It is up to the Principal
Investigator of the project to determine who meets these criteria.
Determinations of Investigator status are distinct from determining PI Eligibility
for proposal submissions.
In addition, the following individuals will always be considered Investigators:
- Principal Investigator, including Multiple PIs (those with equal responsibility for
the project)
- Co-Principal Investigator
- Co-Investigator
- Sponsor for Postdoctoral or Graduate Fellows
- Postdoctoral or Graduate Fellows paid on Fellowships
- Anyone named Senior/Key Personnel on the proposal submission
Subrecipients, while also always considered investigators, must comply with the FCOI
policy of their home institution.
If ANY of following questions can be answered “YES” for an individual, they ARE considered an Investigator.
- Is the individual responsible for the design of any the research?
- Is the individual responsible for the conduct of any the research?
- Is the individual responsible for the reporting of any of the research?
- Is the individual responsible for any programmatic outcomes?
- Will the individual be a collaborator on a publication related to the research? For example: Will they be listed as an author on a publication that cites the award as a ‘Funding Source?’
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Do I need to report my travel reimbursements?
Not if they are received from a U.S.-based academic institution, including KSU. Please
see the policy document for a description of the types of financial interests and income that need to be reported
and which are excluded. Any reimbursements or income from foreign sources does need to be reported regardless of reason (including money from foreign academic institutions). |
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Do I need to include my grants on my disclosure form?
Not if they are received through KSU/KSURSF. Please see the policy document for a description of the types of financial interests and income that need to be reported
and which are excluded. |
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Does income from service as an expert witness need to be disclosed?
Yes, if it relates to your professional expertise and/or University responsibilities because these could indicate a financial conflict. This applies to you, a spouse/domestic partner, or a dependent child, for earnings more than $5,000 in value during the previous 12 months. The outside
entity for the disclosure is the law firm that paid or retained the individual for
the testimony. Please include in the comment section sufficient detail, such as the
companies for which the testimony was solicited, to allow the FCOI Committee to determine
whether it represents a conflict of interest with any of your research projects. |
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Do I need to report patent earnings on my disclosure form?
It depends. If they are earned through KSURSF, then there is no need to indicate it
on the form. Please see the policy document for a description of the types of financial interests and income that need to be reported
and which are excluded. Remember that you need to disclose financial interests of
immediate family members (spouse/domestic partner and dependent children) and any
money from foreign sources. |
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