Conflict of Interest

Memo From Robert A. Brown, Provost

TO: Academic Deans, Laboratory Directors, Department Heads, Administrative Officers

FROM: Robert A. Brown, Provost

DATE: February 1, 2003

SUBJECT: New Process for Submitting NIH/NSF Conflict of Interest Disclosures Available

MIT has developed a secure on-line web-based system to allow principal investigators and other researchers to submit the required conflict of interest disclosure forms for NSF and NIH electronically and confidentially to OSP’s director. This web-based system replaces the paper intensive submission process which has been in place since the requirements were mandated.

This system significantly streamlines the submission of the financial disclosure information required by NSF and NIH and provides a firm foundation if/when the federal government extends the disclosure requirements to other agencies. It provides a method for investigators to submit the documentation from remote locations and to update financial entities on-line. It also provides a simple method to provide annual updates for current awards and pending proposals. As with the paper system, the disclosure information is confidential and limited to the Director of Sponsored Research and the Vice President for Research. The new system was demonstrated to Academic Council in December. In addition, several faculty members piloted the system over the last two months without difficulty.

We encourage investigators to use the system beginning February 1, 2003. The web- based system will be the system of record beginning July 1, 2003. OSP will be delighted to set up group or individual training sessions through the spring semester. Departments, laboratories, and individual investigators may contact coeus-help@mit.edu or call Julie Owens at 3-8048 to schedule a demonstration.

The process for submitting entity and financial disclosure information is described on the attached page. If you have any questions at this time, please contact Julie Norris at 3-2492, Steve Dowdy at 3-6925, or Tom Duff at 3-7086.

RAB/cjh
Enclosure
Cc: Dr. Alice Gast
Ms. Julie Norris

FINANCIAL DISCLOSURE SYSTEM
NIH AND NSF PROPOSALS AND AWARDS
February 2003

The web-based system works as follows:

1. There are two specific types of data requested: i) entity data, which requests information on financial entities which meet the thresholds identified by NSF and NIH, and ii) disclosure data, which requests information for individual NSF or NIH proposals. These two functions request exactly the same information as the current paper-based system.

2. An individual accesses the system at http://coeus.mit.edu/coeus then clicks on “Conflict of Interest Module” which is located on the left-pane navigation menu. The financial entity information needs to be provided only once; the system allows additions and/or updates but does not require multiple submissions of the same data. Since history is maintained, deletions are not allowed. Entities can be marked as “Inactive” in the event the individual no longer has a financial relationship with a previously disclosed entity.

3. The financial disclosure information needs to be submitted with each proposal (as currently done), but the entity data do not have to be reentered or resubmitted.

4. Revisions to the entity information may be done on- line and updated at any time.

5. While not immediately apparent the first time an individual accesses the system, the requirements for submitting an annual disclosure for pending proposals and active awards are also accommodated. Additional instructions and information will be provided during MIT’s annual certification process. Individuals that utilize the new web-based system will be able to take full advantage of the new streamlined annual certification process.

Individuals are encouraged to send e-mail to coeus-help@mit.edu for quick assistance on using the new system or to schedule demonstrations as this address is monitored by several knowledgeable OSP staff members.

Last updated 6/25/03