COI Reporting: When and What

When should I submit a COI report, and what should I include?

When do I need to complete my COI report?

If you are required to complete a COI report (see "Who Needs to Submit a COI Report?"), COI staff will ask you to do so each spring during the annual COI reporting cycle, which runs from mid-April to mid-May.

In addition to the annual reporting cycle, COI reports must be filed using the eCOI reporting system at the following intervals:

  • New Appointments: New academic staff must complete an annual report within one month of their Cornell start date.
  • New Responsibilities: Individuals who become responsible for the design, conduct, reporting, or direct administration of research are required to complete an annual report within one month of assuming these responsibilities.
  • Material Change in Circumstances: All research personnel must update their COI reports within 60 days if any responses to the report have materially changed, such as starting a new company related to your Cornell research; a new consulting relationship; significant changes in income or funding from an entity that you have a financial relationship with; or any other similar change.
  • Proposal or Award-Specific Report: All research personnel must report proposal-specific information and disclose any relationships between that proposal and their external commitments and financial interests at the time the Principal Investigator submits the proposal to the Office of Sponsored Programs (OSP). OSP will not submit a grant proposal if a proposal-specific report has not been submitted by all research personnel. Any resulting award may be distributed only after the proposal-specific reports have been reviewed and any resulting management plan has been implemented.
  • Initiating Licensing Activity: Research personnel are required to report their external commitments and financial interests at the time the Center for Technology Licensing (CTL) begins to negotiate a license for technologies for which the researcher is named as an inventor.
  • New IRB Protocols: As part of a new protocol submission to the Institutional Review Board for Human Participant Research (IRB), non-student Principal Investigators and co-investigators are required to declare if they have any project-related external financial interests. (Note: this is not done through the eCOI system; there are relevant questions asked in the IRB protocol application form.) Any financial interests related to the project must be reviewed and any resulting management plans implemented before the IRB protocol can be approved.

If you have any questions, or run into any problems when trying to update your COI report, visit the eCOI System help page.

What should I include or leave out in my COI report?

You will be asked to report your and your family’s* relationships with independent organizations, private or public companies, foundations, non-profit organizations, industry or trade groups, or international educational institutions with which you have a financial relationship. Applicable relationships include: consulting work; speaking engagements; service on management or advisory boards, or others related to policy, fundraising, or fund management; employment, including in your own company; any intellectual property agreement of which you are a beneficiary; equity interests in private or public companies; and financial gifts from an entity with which you have one of these relationships, if these relationships are related to your Cornell duties.

*Your family’s interests are reported only if they are related to your Cornell duties, as described in your COI report.

The following should not be reported:

  • Cornell and its associated campuses
  • any US federal, state, or local government agency**
  • any non-profit US Institution of higher education as defined at 20 U.S.C. 1001(a)**
  • any US academic teaching hospital, medical center, or research institute that is affiliated with an institution of higher education**
  • Employment or other relationships that occurred before you came to Cornell or after you expect to leave, and do not overlap with your Cornell appointment
  • Volunteer or other work for which you were not compensated, nor promised future compensation for your contribution or participation
  • Awards from external funding agencies (including those from corporations, foundations and international agencies) and executed by the Cornell Office of Sponsored Programs
  • External commitments and financial interests which occurred while you were on sabbatical leave.***

**Note: These types of engagements ARE disclosed in one question regarding conflict of commitment reporting, but should not be included elsewhere in your report.

***Note: Equity interest earned as a result of activities you engaged in while on sabbatical do need to be reported.