Compliance & Integrity
Disclosure Process
Cayuse Outside Interests
Annual and Project related conflict of interest disclosures can be completed via the Cayuse Outside Interests online module. Cayuse Outside Interests serves as a portal to manage all annual COI as well as proposal COI disclosures; as well as forms related to External Professional Activities (EPA). You may access any COI disclosure form or EPA Notice of Intent form through this website.
Please consult the information located on the Outside Interests Module Page for completing the annual disclosure process.
COI Topics Menu
General Disclosure FAQ
Conflicts of Interest and Commitment applies to:
- Faculty (9 month, 12 month, part-time and Emeritus)
- Senior Academic and Administrative Officer (SAAO)
- Exempt Professional Staff (EPS)
- Senior/Key personnel paid by a sponsored research award and engaged in the design, conduct, or reporting of a sponsored research project.
- Individuals who may be required via sponsored project award terms to complete a disclosure.
Conflict of Interest Disclosures should be completed prior to the submission of any funding proposal for any COI that is related to the proposed project. The Office of Research Integrity will now be an integral part of the proposal submission process, verifying that the COI disclosures have been completed for any required individual. Proposals will not be submitted without this being completed, so be sure to log-in to Cayuse and complete this crucial step.
The deadline for completing Annual Disclosures is September 30th. This revised time frame reduces the burden of end-of-the-year administrative tasks, and better aligns with the intent of the disclosure process to be forward thinking (e.g., you are asked to disclose current activities and those anticipated over the next year). Reminders will be sent out to the Campus Community at the start of the Fall semester.
For situations that may generate a conflict that are not research related, those should be disclosed via the Annual COI Disclosure form when the situations arise, and updated during the Annual Disclosure process thereafter. For example, situations involving faculty who own or have an interest in an outside businesses, or engage in a consulting relationship that could potentially overlap with their UNCG teaching or administrative responsibilities.
You should receive an email indicating that your disclosure has been received. The next steps depend on the content of your disclosure:
- If you answered “No” to all questions, then your annual disclosure process is complete.
- If you answered “Yes” to any questions, you will receive a follow-up email indicating whether additional steps (e.g., review by the COI Committee, creation of a management plan) are needed.
- If you have a potential conflict that needs to be addressed immediately, please contact UNCG’s Office of Research Integrity at [email protected].
You can check the status of your disclosure and review prior disclosures at any time by logging into Cayuse, clicking on “My Profile” in the drop down menu under your name on the right hand side of the screen, then clicking on “COI Disclosures” at the bottom of the list on the left. You’ll see a list of all disclosures that you’ve made, their status and submission dates for all Annual and Project-based disclosures.
All disclosures will receive an initial administrative review by COI Staff in the Office of Research Integrity. Department Heads/Chairs, Deans, and other supervisors will continue to play a key role in the determination process when a potential conflict of interest exists; they also will be given a summary report that indicates the Annual Disclosure status for individuals within their units. The Conflict of Interest Official will serve in a case management role, shepherding situations where a potential conflict of interest exists through the review process by coordinating communication and information, providing guidance on policy, and referring cases to the COI Committee when appropriate. For those with known conflicts and/or existing management plans, this also will allow for greater streamlining of the review process.
The main function of the Conflict of Interest committee is to review COI cases that relate to research and other forms of scholarship. The COI Committee primarily reviews COI cases related to externally funded projects. UNCG is required by federal regulations to evaluate, manage, and report conflicts of interest in instances where federal funding is involved. The COI Committee also may review research-related COI when external funding is not involved. This is most likely to happen when human subjects research is involved.
Members of the committee are selected to be representative of the disciplines, but also knowledgeable of the topic at hand (including the COI regulations of not only the UNC system and UNCG, but also multiple federal agencies). Staff in the Office of Institutional Integrity and General Counsel, Office of Sponsored Programs, the Office of Research Integrity, Innovate UNCG, and other offices provide additional expertise and consultation.
- Annually (September 30th deadline)
- At the time of research project proposal
- At each new increment of research project funding
- Within thirty (30) days of discovering or acquiring any financial interests for which disclosure is required
- External Professional Activities (EPA) should be disclosed in the Cayuse system at least 10 days prior to that activity, and included in the annual COI disclosure process.
All disclosures should be made using the Cayuse Outside Interests online system.
- Annual disclosures should be made through the “+ New Disclosure” button in Cayuse. Annual email reminders will be sent prior to the September 30th deadline. (Note: all annual disclosures must be submitted via Cayuse.)
- EPA disclosures, Travel, and Authorship disclosures: should be made through the appropriate links in Cayuse, using the Annual Disclosure Form prior to engaging in the outside activity. These disclosures are self-initiated.
- Project specific disclosures: A separate COI disclosure is required for each research proposal. A COI disclosure must be received from all listed personnel before the proposal will be sent to the funding agency/sponsor.
What Should You Disclose?
Financial Interests include:
- Income received, such as salary, dividends, royalties, payment for services, consulting fees, honoraria, and paid authorships, from an entity other than UNCG by the Covered Individual or Covered Individual’s immediate family.
- Equity or other ownership interest in publicly or non-publicly traded entities (e.g. stock, stock options, warrants, or other ownership interest) held by by the Covered Individual or Covered Individual’s immediate family.
This includes university startups. - Intellectual property rights and interests (including inventorship) upon receipt of income related to such rights and interests; held by the Covered Individual or Covered Individual’s Immediate Family. This includes intellectual property rights assigned to UNCG and subject to a share in royalties related to such rights.
- Travel related to the covered individual’s employment duties, that is not paid for by UNCG. Travel can include registration fees, accommodations, transportation costs, etc.
Financial Interest does not include:
- Income from seminars, lectures, or teaching engagements sponsored by a federal, state, or local government agency, a U.S. institution of higher education, an academic teaching hospital, a medical center, or a research institution that is affiliated with a U.S. institution of higher education;
- Income from service on advisory committees or review panels for a federal, state, or local government agency, a U.S. institution of higher education, an academic teaching hospital, a medical center, or a research institution that is affiliated with a U.S. institution of higher education;
- Income from investment vehicles, such as mutual funds, where a Covered Individual or Covered Individual’s Immediate Family does not directly control or advise the investment decision;
- Any reimbursed or sponsored travel paid for by UNC Greensboro or a sponsored research award to UNC Greensboro; or
- Any travel reimbursed, sponsored or paid for by a U.S. government agency, a U.S. higher education institution, a U.S. academic teaching hospital, medical center, or a U.S. research institute affiliated with a U.S. higher education institution.
Paid or unpaid positions of influence, by you or your family members, with an entity in which the interests of the entity appear related to your institutional responsibilities. This could include you or an immediate family member hold an executive position, serve on the board of directors, scientific or technical advisory board, or any other board of a business or a not-for-profit organization.
Engagement in any situation where you may be working with either a family member or other person in which you may have an interpersonal relationship.
If you or an immediate family member receive any favors, gratuities, or gifts of monetary value from a person or business (foreign or domestic) that is related or potentially related to your responsibilities at the University.
If you or a family member be engaged in any activities or relationships other that could be perceived to have the potential for creating either a conflict or the appearance of a conflict with your University responsibilities
This might include engagement with a foreign talent program in either a paid or unpaid capacity, or consulting or doing volunteer work with an organization that does business with the University or that employs students for whom you have oversight.
Any travel that is reimbursed by an outside entity. Travel can include registration fees, accommodations, transportation costs, etc.
Travel does not include that administered through UNCG or travel reimbursed or sponsored by:
- U.S. federal, state or local government agencies
- U.S. institutions of higher education or U.S research institutes
- U.S academic teaching hospitals; OR
- U.S medical centers that are affiliated with U.S. institutions of higher education.
Situations in which an activity could create a potential conflict of interest or commitment with respect to a faculty member’s mentorship responsibility.
External Professional Activities are those that are:
- not included within one’s University Employment Responsibilities;
- performed for any entity, public or private, other than UNCG; and
- based upon the professional knowledge, experience and abilities for which the University employer employs the employee
Examples would include: private consulting, serving on a board of directors, speaking engagement, etc. These disclosures go to the departmental supervisor for review and approval.
“Organizational Conflict of Interest” (OCOI) means that because of activities or relationships with other entities, the institution is unable to render impartial assistance or advice to the Government, cannot perform the federal contract work in an objective way, or has an unfair competitive advantage compared to other entities.
Organizational Conflict of Interest (OCOI) could result when the nature of the work being performed on a federal contract creates an actual or potential conflict of interest on a future award, which could result in restrictions on that award. There are three basic categories where OCOIs may be found:
- biased ground rules (FAR 9.505-2): Example – preparing/writing specifications or work statements that are used in a funding opportunity;
- impaired objectivity (FAR 9.505-3): Example – evaluating or assessing performance of products/services of others within same organization; and
- unequal access to information (FAR 9.505-4): Example – gaining access to non-public information (i.e., budget(s)/budget information, statements of work, evaluation criteria, etc.) through performance of a federal contract.
If your proposal requires an OCOI attestation, please reach out to [email protected] for more information.