Who Needs to Submit a COI Report?

Am I required to complete a COI report?

Each year, the annual conflict of interest reporting cycle runs from mid-April to mid-May. During that time, COI administrators contact all individuals who are required to report and ask them to do so. If you receive an email directing you to complete a COI report, it is because university policies dictate that you must do so, given your role and/or activities on behalf of Cornell. If you receive one of these emails, do not ignore: these emails are sent only to people who must report. If you have questions about why you must report, contact the COI office as soon as possible. Sanctions will apply if a reporter misses the reporting deadline.

Cornell follows best practices for reporting and management of financial conflicts of interest related to research, regardless of funding. You must complete a COI report if you have an academic title (Professor, Postdoc, Lecturer, Research Associate, etc.) or if you are considered “research personnel,” regardless of funding. This term is defined as “any individual responsible for the design, conduct, or reporting of Cornell research, including key personnel, as well as those responsible for the direct administration of research.”(Direct administration of research is defined as oversight or decision-making impacting research, including: selection of vendors, determining the allocation of funds, sponsor negotiations for the research project, protocol review and approval, or managing resulting intellectual property and licensing opportunities.)

Research personnel who must submit a COI report include:

  • For sponsored research: (1) Principal investigators, co-principal investigators, co-investigators, and any other individual named in a sponsored project budget, narrative, key personnel list, by CV attachment, or noted anywhere else by name in a proposal or award; and (2) Anyone who, during the course of a sponsored project, assumes one of these roles.
  • For non-sponsored research: Those whose role on the research project is synonymous with the roles described above, for sponsored research.
  • For IRB protocols: Non-student principal investigators and co-investigators.