As part of the campus-wide Research Administration Support Systems (RASS) rollout, the current system for submitting Conflict of Interest reports will be replaced with Cornell’s new RASS-COI system. Departments will be brought into the new system on a rolling schedule beginning in December.
Many researchers at Cornell have already been using RASS for sponsored projects and IRB protocols. The new COI reporting will look and feel similar.
RASS-COI includes enhancements to reduce processing delays for sponsored awards and IRB protocols and to improve the reporting process for everyone involved.
Beginning in December, the new RASS-COI system will be rolled out to departments gradually. You will receive an email task notification from RASS-COI when you are required to complete a COI report.
These notifications will be sent incrementally, by department, rather than to the entire university at the same time. You are not required to report until you receive the task notification from RASS-COI. From the date of that notification, you will have 45 days to complete your COI report before sanctions for non-compliance may apply to you.
We will be communicating with department leadership so they can share information about when your department will start using the new system. Refer to the project schedule below for dates.
Note: If you need assistance, the COI staff will have training available.
Research & Innovation Division
College of Agriculture and Life Sciences
Architecture, Art, and Planning
College of Arts & Sciences
College of Human Ecology
College of Veterinary Medicine
Brooks School of Public Policy
SC Johnson College of Business
If you are named on a new sponsored award or IRB protocol, you must complete your COI report before that award or IRB protocol can be processed. Note: This means that you could be asked to report before the date listed in the schedule above for your department to begin using the new system.
If you receive a task notification from RASS-COI to complete a COI report, please complete it as soon as possible; waiting will cause delays in releasing your sponsored award or processing your IRB protocol.
Note: If you need assistance, the COI Office will have training available.
Report only once per year
In the past, Cornell used an annual COI reporting cycle. Everyone completed a COI report at the same time. Even if you had updated your COI report that year, you were still required to report again during the annual cycle.
Cornell is now using a “rolling cycle.” This means that you only need to update your COI report once each year. If you update your COI report at any time throughout the year, the due date for your next report will be reset, and you won’t be required to report again for another year. For example: you complete a COI report in January and then update it in March, your next update is not required until the following March.
Project specific disclosures reduce delays in processing research funds and IRB approvals
If you have both significant financial interests (such as equity or compensation over $5K) and either sponsored awards or IRB protocols, you will now provide project-specific answers for a few questions to help Cornell understand whether there is a relationship that could present a COI issue. These disclosures will reduce delays in distributing your research funds and processing your IRB protocols.
System communications provide clarity
You’ll receive notifications from the RASS-COI system when you have tasks to complete. These will be similar to the notifications you’re already receiving about sponsored projects or IRB protocols and may include:
- COI reporting deadlines
- Notification of project-specific disclosures to complete
- Missed deadlines (which may result in sanctions)
- COI staff questions or comments that require your response
A note about COI reporting requirements and the regulatory landscape: The regulatory landscape in which Cornell operates its research enterprise has significantly evolved and expanded in scope over the last few years. The COI staff and others in the administrative teams of the OVPRI are diligent in responding to this changing environment to protect the integrity of Cornell’s institutional reputation. The newly redesigned RASS-COI report will help to ensure adequate disclosures of “other” support, and management of possible COIs and export-controlled information.
What is a project-specific disclosure?
Project-specific disclosures are updates to your COI report in the form of a few short questions used to indicate relationships between your research and your financial interests. They only need to be completed if you have both significant financial interests (such as equity or compensation over $5K) and either sponsored awards or IRB protocols.
When do I need to complete a project-specific disclosure?
The first time you complete a COI report in RASS-COI: If you are required to complete project-specific disclosures, you will receive an email from email@example.com asking you to do so immediately after you submit your first COI report in RASS-COI. At that time, you will need to log back into RASS-COI and complete a project-specific disclosure linking each of your significant financial interests with each or your sponsored awards and IRB protocols. For example, if you have two financial interests, two sponsored awards, and one IRB protocol, you will need to complete six project-specific disclosures.
When you are named on a new IRB protocol or a sponsored award: At that time, you will receive an email from firstname.lastname@example.org, asking you to complete a project-specific disclosure. If you do not have a current COI report on file at that time, you will need to complete one in addition to your project-specific disclosure. Until you do so, your IRB protocol or your sponsored award will be on hold, and the monies associated with your sponsored award will not be disbursed.
When you report a new significant financial interest: Reporting certain types of financial interests, such as equity or compensation above $5K, will trigger the need for a project-specific disclosure. When you report such financial interests, you will receive an email from email@example.com asking you to complete a project-specific disclosure linking that financial interest with each of your sponsored awards and IRB protocols.
This new process seems burdensome to me. Why do I need to do it?
We understand that the project-specific disclosure process may seem burdensome, especially for researchers with multiple significant financial interests, sponsored awards, or IRB protocols. However, project-specific disclosures are critical to identifying conflicts of interest related to your research so that we can help you manage them. This in turn improves the processes in place that protect researchers and the integrity of research at Cornell. Completion of project-specific disclosures will also lead to far fewer delays in processing your sponsored awards and IRB protocols, and will reduce interruptions to your research activities due to compliance screening processes.
We’re here help. Please reach out to us at firstname.lastname@example.org if you need assistance completing your project-specific disclosures.
I submitted my COI report and then immediately got an email telling me to complete a project-specific disclosure. Why?
Whether or not project-specific disclosures are required of you depends on what types of financial interests you report. Until you submit your COI report, the RASS-COI system has no way to determine whether you’ve reported anything that requires the completion of a project-specific disclosure. When you submit a report in which you’ve disclosed things such as equity interests or compensation above $5K, you will receive an email from email@example.com asking you to complete a project-specific disclosure if you are also named on sponsored awards or IRB protocols.
One research administration support system for Sponsored Research, IRB, and COI
When RASS-COI is live, Cornell will be using one system for Sponsored Projects, IRB, and COI. One shared system increases transparency, reduces the time required to distribute your research funds and process your IRB protocols, improves compliance with federal regulations, and allows for research administration at Cornell to function more efficiently and effectively, while continuing to adjust to changing regulations and expectations from our partners.