Conflict of Interest

coiKennesaw State University complies with federal regulations ensuring that sponsored activities will not be compromised by investigators’ financial interests that could be reasonably expected to bias the design, conduct, or reporting of the research. In accordance with these regulations, the University has the responsibility to disclose, manage, reduce, or eliminate any actual or potential conflicts of interest that may be presented by a financial interest of an investigator.

There are two required elements for FCOI compliance:

  1. COI Training – via CITI, valid for 4 years
  2. Disclosure (or affirmation of nothing to disclose) – via Cayuse
    To be updated annually or within 30 days of acquiring a new financial interest

You can check your status for each of these easily in your Cayuse profile:

  1. Click on “Training & Certifications” in the left panel and look for the expiration date for the “Conflict of Interest mini-course.” Note that each time you refresh any given training you will have a new line for the same course.
  2. Click on “COI Disclosures” and check the date of your last disclosure submission. It should be from the current calendar year.
  • KSU has a uniform policy for financial conflicts of interest in research. Reporting requirements vary by research sponsor, but our annual disclosure requirements are the same for all researchers, to ensure that we comply with all potential sponsor’s regulations. Please note that you still need to report outside activities through the portal on OwlExpress. The FCOI policy for research only fulfills the reporting requirements of research sponsors and will not communicate any outside activities to your Chair or Dean.

    It is expected that investigators update their disclosures annually. You are also required to update your disclosure within 30 days of acquiring a new reportable financial interest.

  • As part of our conflict of interest policy, we require that investigators on a research team with outside support and a sponsor COI reporting requirement complete training. Our training is available through CITI and is valid for 4 years. Please see the instruction sheet to add the COI course to your CITI profile. See here for the full list of CITI training available via KSU.

  • All investigators must disclose their significant financial interests as defined in the policy at least annually. Please log in to the Cayuse Research Suite to complete your annual disclosure. Please note that this is not the same server that is used for IRB submissions or for proposal administration. Instructions and a walkthrough of the disclosure process are provided. You will file your disclosures from your Profile page in Cayuse. 

  • All faculty (including part-time and limited-term) are granted access to Cayuse automatically, via NetID and password. 

    Staff and students who receive “Forbidden” or similar errors when trying to log in will need to request Cayuse access. Fill out this form and enter “COI” in the Research Group Head field. You will receive an email confirmation once your profile has been created.

  • Most investigators should file an “Annual Disclosure.”

    The National Science Foundation currently requires grant recipients to file specific COI disclosures for each funded project. Please log in to the Cayuse Research Suite and complete a “Research-based Disclosure” if you are applying for/have received NSF funding or are otherwise requested to do so by Sponsored Programs.

  • Each January, federally funded investigators will be reminded to update their disclosures for the calendar year. Please remember that all investigators on the project also need to disclose any significant financial interests as required by federal research sponsors (see “Who needs to file an FCOI Disclosure?” below). In July, there will be a second check of disclosure and training status to ensure that all new awards are up to date. Appropriate notifications to College administration and consequences will follow continued non-compliance. The reminder process is detailed in this document
  • Please contact with any questions about COIs or disclosures, and with any technical issues. 

    Cayuse works best with Chrome or Firefox.

    Cayuse has a robust support website that is free (registration required) with information and walkthroughs of different tasks. These are also accessible through the help icon (Orange question mark) at the bottom right when you are logged in to Cayuse.

  • The Public Health Service (i.e., NIH) regulations, and the KSU FCOI policy, indicate that anyone who is an Investigator on a project needs to receive training and file a COI disclosure. An Investigator is the project director or principal investigator and any other person, regardless of title or position, who is responsible for the design, conduct, or reporting of research, which may include, for example, collaborators or consultants. Investigator includes, but is not limited to, the Principal Investigator, project director, co-principal investigator, and may also include other Senior/Key Personnel, a postdoctoral fellow, graduate student, trainee, staff member, collaborator, or consultant, depending on the person’s role in the research.

    The primary factors to be used in determining who is an Investigator are the significance of the tasks assigned to the individual regarding the design, conduct, and reporting of the research and the degree of independence that individual may have in performing such research-related tasks. The Public Health Service (PHS) Financial Conflict of Interest (FCOI) regulation applies to all individuals defined as project Investigators. It is up to the Principal Investigator of the project to determine who meets these criteria.

    Determinations of Investigator status are distinct from determining PI Eligibility for proposal submissions.

    In addition, the following individuals will always be considered Investigators:

    • Principal Investigator, including Multiple PIs (those with equal responsibility for the project)
    • Co-Principal Investigator
    • Co-Investigator
    • Sponsor for Postdoctoral or Graduate Fellows
    • Postdoctoral or Graduate Fellows paid on Fellowships
    • Anyone named Senior/Key Personnel on the proposal submission

    Subrecipients, while also always considered investigators, must comply with the FCOI policy of their home institution.

    If ANY of following questions can be answered “YES” for an individual, they ARE considered an Investigator.

    • Is the individual responsible for the design of any the research?
    • Is the individual responsible for the conduct of any the research?
    • Is the individual responsible for the reporting of any of the research?
    • Is the individual responsible for any programmatic outcomes?
    • Will the individual be a collaborator on a publication related to the research? For example: Will they be listed as an author on a publication that cites the award as a ‘Funding Source?’
  • Not if they are received from a U.S.-based academic institution, including KSU. Please see the policy document for a description of the types of financial interests and income that need to be reported and which are excluded. Any reimbursements or income from foreign sources does need to be reported regardless of reason (including money from foreign academic institutions).
  • Not if they are received through KSU/KSURSF. Please see the policy document for a description of the types of financial interests and income that need to be reported and which are excluded.
  • Yes, if it relates to your professional expertise and/or University responsibilities because these could indicate a financial conflict. This applies to you, a spouse/domestic partner, or a dependent child, for earnings more than $5,000 in value during the previous 12 months. The outside entity for the disclosure is the law firm that paid or retained the individual for the testimony. Please include in the comment section sufficient detail, such as the companies for which the testimony was solicited, to allow the FCOI Committee to determine whether it represents a conflict of interest with any of your research projects.
  • It depends. If they are earned through KSURSF, then there is no need to indicate it on the form. Please see the policy document for a description of the types of financial interests and income that need to be reported and which are excluded. Remember that you need to disclose financial interests of immediate family members (spouse/domestic partner and dependent children) and any money from foreign sources.