Effective November 28, 2016, ORS will launch the new myGRANT COI module. For those investigators who do extramurally-funded work, the COI module will replace the annual paper disclosure form required of all UH employees by UH Administrative Procedure A5.504. The new module will ensure that UH addresses any potential or actual conflicts of interest that may arise during extramurally-funded activities. Investigators are highly encouraged to complete a COI disclosure as soon as possible to prevent the delay of any proposals or awards.
Effective November 28, 2016, the record an investigator makes in the COI module will stand as their valid disclosure of record for 365 days from the date of its completion. This eliminates the need for most investigators to make a disclosure each time a proposal is submitted. Instead, during the proposal process, investigators will simply be presented with a question regarding whether or not their disclosure is up-to-date. Principal investigators will also be asked to confirm that all personnel responsible for the design, conduct, or reporting of the the project will submit their disclosure prior to the start of the project. For those investigators with Significant Financial Interests (SFI), an update to their COI module disclosure will be necessary at the time a proposal is made, and again at the time an award is received.
In contrast with the old annual form, the COI module was designed to streamline the disclosure process and only collect information that is necessary to comply with federal COI regulations and many sponsor requirements. Key information that investigators will need to enter include:
- SFI of the investigator or their immediate family that may appear to be related to any of the investigator’s institutional responsibilities.
- The nature and amount of any SFI disclosed, including the non-UH financial entities involved, and how the SFI is related to any extramurally-funded activities an investigator has.
- Whether or not an investigator or their immediate family have a financial interest in any contract or purchasing negotiation, or any other financial transaction with a non-UH entity that may create a potential conflict of interest.
To access the COI module, logon to myGRANT and navigate to the my COI Dashboard as shown below:
After the investigator submits their disclosure in the COI module, the disclosure information will be directed to the investigator's immediate supervisor for review, as required by UH policy. Immediate supervisors are encouraged to carefully review the disclosure, and input any comments or questions relative to the disclosure in the module that will assist ORS in the review process. Immediate supervisors are highly encouraged to use this interactive process to vet any potential conflicts.
An online tutorial and user guides for the COI module are available at: http://www.ors.hawaii.edu/index.php/coi-webinars
Attend a COI module drop in workshop and complete your disclosure while you’re there.
Please find relevant UH policies and procedures at the following links:
Executive Policy E12.214, “Conflicts of Interest and Commitment”
Administrative Procedure A5.504, “Procedures for Disclosing and Addressing Conflicts of Interest and Commitment”
Administrative Procedure A8.956, “Financial Conflicts of Interest (FCOI) for Public Health Services (PHS) Grants, Cooperative Agreements and Contracts”