Electronic Conflict of Interest Assurance and Reporting
Conflict of Interest (COI) reporting is conducted annually and at “transactional” time points via InfoEd. When submitting COI assurance and reporting forms, it is important to remember that reporting criteria and thresholds are not limits on what type of activities faculty can engage in or how much money one can receive for such activities. Rather, these are criteria and thresholds at which an interest or activity has to be reported to the University. Click here for guidance on how outside activities should be conducted and what is or is not permissible.
The Brown University Conflict of Interest (COI) Policy for Officers of Instruction and Research requires that members of the Brown faculty and Brown Investigators complete an Assurance of Compliance annually. The annual COI cycle runs between the end of February and the end of March. Annual reporting is conducted electronically through InfoEd.
When the annual cycle kicks off in February of each year, anybody who is required to complete the annual Assurance of Compliance will receive an email with instructions and a link to InfoEd. The information collected is for the previous calendar year (January – December), to align with the receipt of income forms/statements and preparation of taxes. If you have questions about the annual reporting cycle, please contact Juliane Blyth or Rebecca Haworth.
New faculty at Brown University
If you are a new faculty member joining Brown at any point during the academic year, you may be asked to complete a COI Assurance of Compliance. Please check your appointment letter to confirm if you are required to complete COI reporting. To submit your Assurance of Compliance, please visit Brown's electronic COI system, InfoEd. If you have questions or need help, please contact Juliane Blyth or Rebecca Haworth.
Investigator on a grant application funded by the Public Health Service (PHS), NSF, or foundations that follow PHS COI regulations
If you are an investigator on a grant application that is funded by PHS or a foundation that follows PHS COI regulations, you will be asked at proposal submission time to confirm that you have submitted an annual COI Assurance of Compliance, and that you reported to the University a complete and accurate list of your significant financial interests for the prior 12 months (from the date of proposal submission). To check the list of your reported interests, please go to the COI module in InfoEd, review your last submission and update the information if necessary. If you have never completed a COI Assurance of Compliance, please go to the COI module in InfoEd to submit. If you have questions or need help, please contact Juliane Blyth or Rebecca Haworth.
Reporting new significant financial interests (SFIs) within 30 days of acquisition
Investigators participating in PHS funded research, or research funded by a foundation that follows the PHS COI regulations, are required to submit an updated disclosure of significant financial interests within 30 days of discovering or acquiring a new significant financial interest (SFI). This is a requirement under federal COI regulations. To submit an updated disclosure, access the COI module in InfoEd. If you have questions or need help, please contact Juliane Blyth or Rebecca Haworth.
Reporting Reimbursed or Sponsored Travel
Investigators who are participating in PHS funded research, or research funded by a foundation that follows the PHS COI regulations, are required to report to the University the occurrence of any reimbursed or sponsored travel.
Reimbursed travel is travel for which the investigator is directly reimbursed by the sponsoring entity.
Sponsored travel is travel that is paid directly by the sponsoring entity and is not reimbursed to the investigator. For example, a professional organization in Switzerland pays directly for your flight and hotel expenses when you attend the organization’s conference as an invited speaker.
This disclosure requirement does not apply to:
Any travel reimbursed, sponsored or paid for by a U.S. government agency, a U.S. higher education institution, a U.S. academic teaching hospital, medical center, or a U.S. research institute affiliated with a U.S. higher education institution; and
Any travel reimbursement or payment of travel made by Brown University, another university college, department or unit, or travel covered by a sponsored research agreement managed through OSP or TVO.
The institution can establish internal thresholds for reporting and reviewing travel. At Brown, the threshold has been set to $5,000 for any 12 month period. This means that you only need to report, within 30 days, any travel that is/was sponsored or reimbursed by an outside entity and:
Is related to your institutional responsibilities or professional expertise, AND
Had an aggregate value of more than $5,000 during the past 12 months.
The $5,000 threshold does not mean that an investigator cannot have sponsored or reimbursed travel of more than $5,000. Rather, it means that any travel that exceeds this threshold must be reported.
To report reimbursed or sponsored travel with an aggregate value of more than $5,000 during a 12-month period, please go to InfoEd. If you have questions or are unsure if this requirement applies to you, please contact Juliane Blyth or Rebecca Haworth.