COI/COC Disclosure Requirements and Annual Certification

Disclosure Obligations

Individuals should disclose potential conflicts of interest and commitment when carrying out their external and University education, research, scholarship, or service responsibilities.  All external relationships, domestic and international, should be transparent and must be disclosed in a manner that is consistent with applicable requirements, including federal and state laws/regulations/agency guidance, as well as Emory University’s policies and procedures. 

Significant Financial Interests (SFI) requiring disclosure are interests held individually by the investigator, their spouse or same-sex domestic partner, and dependent children must be added together, and the aggregate value used to determine limits set forth below:

One or more of the following financial interests held by an Investigator/Key Personnel, their spouse, or dependent children:

  • Remuneration or honoraria over $5,000 from an entity within a 12-month period
  • Ownership interests valued over $5,000 in a publicly traded entity
  • Any ownership interests in a privately held entity (e.g., start-up companies, LLCs)
  • Any intellectual property fees and/or royalties
  • Holding any management positions in a non-Emory entity (director, officer, trustee, management employee)
  • Sponsored travel over $5,000 (except from Emory, U.S. government, higher ed, academic medical centers)

 The following items are NOT considered to be a Significant Financial Interest:  

  • Salary or other payments for services from Emory University 
  • Gifts to Emory University provided the Investigator does not have signing authority for the Emory account. 
  • Income from non-promotional educational seminars, lectures, or teaching engagements sponsored and paid for by governmental entities. 
  • Income from service on advisory committees or review panels established by and paid for by governmental entities.
  • Travel paid by Emory

What if a Potential COI is Determined?

If the Conflict of Interest Committee (COIC) determines that a potential or actual conflict of interest exists for one or more of your outside activities, you are expected to:

  • Respond promptly to follow-up questions from the COI Committee
  • Review and act on a COI management plan. 
  • Complete an annual certification of the conflict situation/management plan

What is a COI Management Plan?

The management plan is a key component of this process. It is a document that outlines and implements measures to actively reduce, mitigate, or eliminate an actual, potential, or perceived conflict of interest held by an employee.

What is a COI Annual Certification?

During COI ANNUAL CERTIFICATION you will be asked to update your discloser profile by answering  a series of questions via eDisclose and submitting updated information to the COI Office. This information may include, but is not limited to:

  • Updating the list of people working on the project (i.e.,  Emory personnel, students/trainees, personnel from the external organization)
  • Listing any new intellectual property related to the project that was filed since the plan’s implementation or previous annual review
  • Entering the statement you will use/have used to disclose the conflict of interest to students, etc., and in publications or presentations

Who is Required to Complete an Annual COI Disclosure Certification?

  • All faculty (including adjunct faculty; and emeritus faculty who are participating in a sponsored project)
  • Postdoctoral scholars
  • Research personnel engaged in the design, conduct, or reporting of sponsored research (including part-time and temporary employees)

When is My Annual Certification Due?

The annual certification cycle is from December 1, 2023-February 29, 2024. Emory University Conflict of Interest (COI) in Research Policy requires that members of the Emory faculty, as well as all Investigators on Emory administered research complete a COI Reporting Form annually. Annual reporting is conducted electronically through eDisclose.

For more detailed information visit our Annual Certification SharePoint Page.

How Do I Disclose?

You will submit a disclosure profile in the eDisclose system, accessible via https://ediscloseemory.huronresearchsuite.com/

  1. Enter your Net ID
  2. Enter your Net ID password
  3. Click on the Sign In button to log in
    Further instructions for completing/updating the disclosure profile can be found here: <<link to user guide for returning disclosers>>

Please note, that if you have not previously logged into eDisclose, you will receive an “Authentication Error” message from the system. To access the system, you will need to submit an account request via this link.