Office of Research

FAQ

How long will it take to complete the form?

Depends on whether you have any interests to disclose.  If you have nothing to disclose it will take approximately 5 minutes to complete and certify.

What happens after I submit my disclosure form?

The form is reviewed for completeness and accuracy and the COI Administrator will determine whether a potential conflict of interest exists and if it requires further review. Further review will include members of the PHS-COI Committee and, if a conflict of interest exists, a COI management plan which involves your Department Chair and Associate Dean for Research.

I don’t have a COI, why do I have to complete a disclosure form?

Confirming that you do not have any potential conflicts by completing a disclosure form is part of the University's conflict of interest oversight process and key to demonstrating the University's management of potential conflicts. It is also the responsibility of the Institution rather than individuals to determine whether a COI exists between your research and financial interests.

How often do I have to disclose my financial interests?

Anyone required to complete a disclosure form must do so annually, within 30 days of discovering or acquiring a new SFI, and when changes occur in the circumstances of a financial interest or outside activity what was previously disclosed.

Who determines if a conflict of interest exists?

The PHS-COI Committee is responsible for identifying conflicts of interest with any PHS funded proposals.  The PHS-COI Committee determines that a COI exists if there is a reasonable expectation that an investigator’s significant financial interest could influence the conduct of Clemson University research.

If I disclose a SFI, will it delay submission of my proposal?

All investigators listed on the proposal must complete a disclosure form prior to submission of a proposal for research funding. Once disclosure has been made, the submission of a proposal will not be delayed for COI reasons. If a disclosure is determined to relate to the research within the proposal, awarded funds may be held until the potential conflict is managed.

If it is determined that I have a COI, will it affect the acceptance of an award?

Prior to the expenditure of research funds where the research relates to a conflict of interest, the conflict must be managed. An award that relates to a conflict of interest can be accepted, but may be held until the conflict of interest is managed. Each conflict of interest has unique circumstances and the expenditure of funds will be dependent on the nature of the conflict and the nature of the award.

What is a COI Management plan?

Once a conflict of interest has been identified, the COI Administrator and Committee will consult with you, your Department Chair and Associate Dean for Research to design a plan of conditions or restrictions to manage the conflict of interest. You will have the opportunity to review and accept this plan. This is called a COI Management Plan.

Will my information be kept confidential?

Clemson University must make certain information available concerning identified FCOIs held by senior/key personnel via a publicly accessible website or by a written response to any requestor within five business days of a request. PHS defines “senior/key personnel” as the project director or Principal Investigator and any other person identified as senior/key personnel by the Institution in the grant application, progress report, or any other report submitted to the PHS by the Institution. At a minimum, Clemson University must provide the following information:

  • Investigator's name;
  • Investigator's title and role with respect to the research project;
  • Name of the entity in which the Significant Financial Interest is held;
  • Nature of the Significant Financial Interest; and
  • Approximate dollar value of the Significant Financial Interest (dollar ranges are permissible: $0-$4,999; $5,000-$9,999; $10,000-$19,999; amounts between $20,000-$100,000 by increments of $20,000; amounts above $100,000 by increments of $50,000) or a statement that the interest is one whose value cannot be readily determined through reference to public prices or other reasonable measures of fair market value.

Why do I have to complete another form if I completed one last year?

Since outside activities and financial interests change, federal regulations and University policy require that disclosure be made on an annual basis.

To aid in facilitating easy and efficient COI disclosure, the online system has several key features:

  • The expiration date on your form is a year from your most recent submission. If you update your form mid-way through the year, your expiration date is reset.
  • 30 days before your form expires, you will receive a notification that your form is expiring soon.
  • Previous disclosures will automatically be copied to your next draft within InfoEd.