If you are able log in to Cayuse Platform but you have other questions that are not addressed here, please contact COI@oregonstate.edu directly.
Answers to frequent inquiries can be found below.
A Conflict of Interest (COI) exists when an individual's personal interests affect - or appear to affect - their professional responsibilities and judgement as a member of the university.
A Research Conflict of Interest (RCOI) exists when a Significant Financial Interest (SFI) could directly and significantly affect the design, conduct, outcomes, or reporting of research affiliated with the university. RCOI is the university equivalent to the regulatory definition of Financial Conflict of Interest (FCOI).
The existence of a conflict of interest increases the potential for bias, and that risk may or may not be recognized by the individual with a conflict.
In some cases, an individual's external or personal interests may tempt them to act in ways that allow their interests to exert undue influence on their work activities and responsibilities at the university. Note, however, that the existence of a conflict of interest does not necessarily indicate that an external or personal interest is unduly influencing their work at OSU.
Individuals with external or personal interests that are in conflict with their obligations and responsibilities at the university can protect themselves when they promptly and accurately disclose their interests to the university, manage them appropriately and in concert with a disinterested party for as long as the conflict(s) exist, and otherwise avoid unnecessary or unmanageable conflicts.
"Investigator" means an individual who has (or will soon be) responsible for a significant aspect of the design, conduct, outcomes, or reporting of research affiliated with the university.
"Investigator" always means principal investigators (PIs), co-investigators, and senior/key personnel who seek or receive support for OSU-affiliated research activities and programs.
It also includes any other individual with research responsibilities who meets the definition above.
Individuals who help administer research or perform research activities, but do not have direct responsibility for the research, are not considered to be Investigators in this context.
"Active Investigator" means an Investigator who is affiliated with one or more research funding proposals, agreements, contracts, or awards that are active/not closed out.
"Research" includes basic and applied research; development of technologies, products, and processes; and the education and training of others in research and development activities, projects, and programs. Research includes any activity, project, or program for which research funding can be sought.
"Entity" means any person, business, company, organization, institution, agency, or government. An entity may be U.S.- or non-U.S.-based, privately- or publicly-held, or hold a for-profit or non-profit tax status.
▪ “Private entity” refers to a business with stock or other ownership interests which cannot be bought or sold by the public
▪ “External entity” refers to any entity other than Oregon State University.
▪ “Foreign entity” refers to any business, organization, agency, university, government, or other entity that is registered or incorporated to do business outside of the U.S.
Financial Interests include, but are not limited to:
b. Equity or other ownership interests (e.g., shares, stocks, stock options) in an entity
c. Intellectual property rights and interests (e.g., patents, trademarks, copyrights)
d. Sponsorship or reimbursement of travel- and lodging-related expenses
Financial Interests do not include:
a. Remuneration received directly from Oregon State University for carrying out university responsibilities
b. Remuneration received for Investigator-provided seminars, lectures, teaching engagements, or services provided to advisory committees or review panels, when provided by:
U.S. Federal, state, or local governmental agencies; or, U.S. institutions of higher education and their affiliated research institutes, academic teaching hospitals, and medical centers located within the U.S.
c. Income or equity held in blind trusts, or consolidated investment vehicles such as mutual funds, as long as the Investigator and their family member(s) do not directly control the decisions made in those investment vehicles.
Significant Financial Interests (SFIs) means financial interests that:
1. are related, or appear to be related, to the Investigator’s research or university responsibilities;
2. were received or held by the Investigator or their family members during the 12 months prior to disclosure; and,
3. when aggregated across the Investigator and their family members for the duration of the previous year, meets one of the thresholds below:
a. Any amount of equity (shares, etc.) in a private entity
b. $5,000 USD or more of equity (stocks, etc.) in a public entity
c. $5,000 USD or more of remuneration from a single entity
d. $5,000 USD or more of aggregated financial interests received by or held in a single entity
If there is any question about whether a significant financial interest could be related to an Investigator’s research or university responsibilities, then that financial interest must be disclosed promptly to the university so a determination can be made by a disinterested party.
Family Member(s) means an Investigator’s spouse or domestic partner, and any of their dependent child(ren).
University or institutional responsibilities means the Investigator’s obligations and responsibilities associated with their university employment or appointment.
This may include activities involving research and research consultation, teaching, advising, clinical or professional practice, administrative duties, university service on committees and panels, and university-based outreach and engagement.
More information may be available in an individual's position description, program expectations, or other agreement with the university.
If you are an active Investigator, then yes, you must complete and maintain a current research-based disclosure at OSU for as long as you remain active in university-affiliated research activities and programs.
"Investigator" includes all principal investigators, co-investigators, and senior personnel who are listed on active research funding proposals, agreements, contracts, and awards that are not closed out.
"Investigator" also includes anyone who is responsible for a significant aspect of the design, conduct, outcomes, or reporting of research, regardless of that person's position or title.
The principal investigator associated with the work determines the level of responsibility for each research team member, and determines whether a research team member qualifies as an "Investigator".
"Research" includes basic and applied research; development of technologies, products, and processes; and the education and training of others in research and development activities and projects. "Research" includes any activity or program for which research funding can be sought.
Yes. All active Investigators must complete their initial research-based disclosure in Cayuse Platform prior to June 15, 2022.
iRIS is no longer used for research COI disclosure submissions or management. However, you will still have access to your disclosures in iRIS until December 31, 2022.
If you are an active Investigator, then yes, you must complete research COI training, and take a refresher course at least once every four years to remain current, for as long as you remain active in university-affiliated research activities and programs.
Research COI training must be completed:
(1) upon initial identification as an active Investigator,
(2) least every four years thereafter as an active Investigator, and
(3) upon request by the RCOI Officer, a supervisor, or other university official.
This fulfills the training standard described in the U.S. Public Health Service regulation on Financial Conflicts of Interest in Research.
If you don’t have any financial interests to disclose, logging in to the system and completing a research-based disclosure should take approximately 5 minutes.
If you have new financial interests to disclose, then the time needed will be variable and dependent on your situation.
The good news is, once the information is entered into the research-based disclosure in Cayuse Platform, it is saved and will populate your future research-based disclosure forms. You will only need to review and update that information, which should reduce the time needed to complete your future disclosures.
Holding stock or shares in a company that supports your university research
Holding a position in a company or organization that supports your university research, such as:
• Office or membership on a board of committee
• Director, officer, partner, trustee, employee, or management
• Founder, co-founder, or shareholder
Accepting the following from a company or organization that supports your university research:
• Travel reimbursement to attend board meetings.
• Honoraria for presentations at companies or organizations whose financial interests could be affected by your university research.
• Income, gifts, or loans
• Consulting income where the consulting activity could reasonably appear to be related to a research project.
Holding a financial interest in a company that:
• Develops, manufactures, or improves a product, or offers services that are related to a research project.
• Will act as a vendor, subcontractor, lessor, or other participant on a research project.
• Is related to intellectual property (IP) in which you are named as an inventor, if a research project could reasonably appear to be affected by the interest.
An active Investigator must disclose their financial interests initially:
• Within 30 days of appointment, when the Investigator will be responsible for one or more active research proposals, projects, programs, or awards within the first year, or
• Prior to submission of their first research funding proposal as an Investigator, or
• Upon request by the RCOI Officer, their supervisor, or other university official.
Thereafter, Investigators must disclose their financial interests to the university:
• Within 30 days of discovering or acquiring a new significant financial interest (SFI),
• On an annual basis, whether or not they have any financial interest(s) to disclose, and
• Upon request by the RCOI Officer, their supervisor, or other university official.
During review, additional information may be requested in order to determine whether a research conflict of interest exists, and if so, determine how to reduce, manage, or eliminate the conflict(s).
Additional information may be gathered from the Investigator, and from other sources such as university websites, research-related websites and databases, outside entity websites, and other sources of publicly available information, on an as-needed basis.
The RCOI Officer (who also serves as the Associate Vice President for Research Integrity) is responsible for identifying research conflicts of interest, as the university's primary disinterested party in these matters.
Disclosures undergo preliminary review within the RCOI program office, and at the RCOI Officer’s discretion, ad hoc reviewers and evaluators provide advice and feedback on research conflicts of interest and their management.
A research COI exists if there is a reasonable expectation that an Investigator’s significant financial interest could unduly influence or bias OSU-affiliated research.
Conflicts of interest are common in research, especially in light of increased support for university and industry collaborations. Research conflicts of interest are not inherently bad and can exist as long as they are managed appropriately to protect the integrity of OSU research.
If you have a research COI, the RCOI program office will work with you to develop an appropriate plan to manage, reduce, or eliminate the conflict.
If a research conflict of interest cannot be appropriately managed or eliminated, then the OSU research may not proceed.
Failure to comply with this policy may lead to disciplinary action, up to and including termination of appointment in accordance with applicable disciplinary procedures.
Possible violations that may lead to disciplinary action include, but are not limited to:
1. Failure to maintain current training or maintain a current research-based disclosure;
2. Failure to fully disclose external financial interests or a potential conflict of interest in research;
3. Failure to comply with a conflict management plan;
4. Failure to respond to inquiries from the RCOI program office or Officer.
Examples of actions or sanctions that could be applied include but are not limited to:
1. Requiring the completion of additional training or coursework regarding financial conflicts of interest in research
2. Involvement of an appropriate supervisor
3. Review of whether the research was biased in its design, conduct, outcomes, or reporting
4. Review of whether information about the research was inappropriately shared with one or more external entities
5. Notification of research sponsor(s) regarding policy noncompliance and university plan to resolve the issue(s)
6. Suspension of researcher from participating on one or more research project(s)
7. Suspension of a researcher from submitting additional research funding applications
8. Recommendation of disciplinary action(s), including postponement of promotion activities, suspension of employment, or termination from the university
The research COI policy addresses conflicts of interest between outside financial interests and their potential to influence the design, conduct, outcomes, and reporting of OSU-affiliated research.
Yes. Any income, travel or lodging sponsorship, or other financial interests that involve foreign entities, including government agencies, for-profit and non-profit organizations, and institutions of higher education and research, must be described in your research-based disclosure when the threshold of “significant financial interest", or SFI, is met.
If you have a financial interest, but are unsure as to whether it meets the threshold for disclosing, we recommend disclosing the interest as a good-faith effort to ensure transparency.
You must also disclose your outside professional activities and entity relationships according to OSU's Policy on Conflicts of Commitment, utilizing a Request for Approval of Outside Professional Activities form.
Finally, it may be useful to review the following university webpages:
International Research and Academic Research Collaborations: Letter from Dr. Irem Y. Tumer, Vice President for Research (13 June 2019)
Conflicts between time spent on outside professional activities and university responsibilities are governed by the Conflict of Commitment Policy. The COC policy is overseen by the Office of Academic Affairs and details the type of activities that can be conducted during University time and with the appropriate approval.
Working with a family member or a member of your household is governed by the Human Resources policy on Nepotism and an Oregon Administrative Rule. Both policies can be found at the Human Resources website under Nepotism, https://hr.oregonstate.edu/manual/employment-and-supervision-family-members-nepotism.
As part of the procurement or contracting process, Procurement and Contract Services (PaCS) addresses procuring from or contracting with entities that an individual has a financial or other personal interest. Section 104-001 of the Procurement and Contract Services Policy and Procedures Manual details the Declaration of Conflict or Potential Conflict of Interest.
Having a conflict of interest or the perception that a conflict of interest exists, can harm the trust that the public has in the university and the research conducted by investigators of the university.
The research COI policy protects you, the integrity of your research, and the integrity of the university research mission.
In addition, federal regulations require institutions to implement such a policy, in order to receive federal funding for research.
1. Federal regulations require it. Federal funding agencies require award recipients to disclosure their outside interests to promote objectivity in research.
2. Disclosing external financial interests provides protection for you as an Investigator, as well as the university.
Maintaining an accurate and up-to-date research-based disclosure with the university helps to identify and mitigate risks of undue influence or bias associated with external financial interests. This, in turn, protects the validity and objectivity of the product of your scholarship, and preserves the integrity of the university's academic enterprise and business decisions.
In order to determine whether a financial interest could influence the design, conduct, reporting, or oversight of research, the RCOI Program must ensure that your interests are reviewed in light of your OSU research activities, roles, and responsibilities.
The RCOI Program employees and the RCOI Officer have access to all disclosure information. Based on the type and nature of financial interests involved, additional people may be asked for input and provided access to your disclosure, including your supervisor, RCOI consultants at OSU (such as OSU Advantage, General Counsel, Human Resources), and your department head/chair/director and dean/vice provost/vice president. Within constraints imposed by state law, all information that is disclosed in considered part of your confidential personnel record.
All Investigators must ensure that their research-based disclosure is accurate and up-to-date, prior to submission of a proposal for research funding.
If all Investigators on a proposal or award have current research-based disclosures in Cayuse Platform and current COI training in CITI, then there will not be a submission delay for research COI reasons.
An award that relates to a research conflict of interest can be accepted, but the creation of an index for spending funds may be held until the research conflict of interest is managed.