Conflicts of Interest Guide for Research and Sponsored Programs
WHO must submit a COI disclosure?
UT System Policy GE0002 – Conflicts of Interest and Commitment requires all UTC faculty, staff, and graduate students holding assistantships to annually file & maintain an up-to-date disclosure of outside interests and activities.
HOW do I disclose?
COI Disclosures must be submitted and updated in DASH. Help guides are available on ORI’s RCOI webpage.
WHAT should I disclose?
Any outside interest or activity. Examples include foreign engagements/appointments, external employment, private consulting, board service, sponsored travel, IP rights, venture capital, equity, prizes, etc. Please review the UT Policy Guidance documents What to Disclose and Disclosures for Research Activities.
NOTE: You must select “YES” to the question Do you have any financial interests and/or outside activities? on the Entity Disclosure Information tab in order to add an interest or activity to the form.
WHEN should I disclose?
| Within 30 days of employment start date | All new employees, including graduate assistantship holders, must submit an initial COI disclosure. |
| ASAP whenever there is anything new to disclose | This process is meant to be proactive in order to prevent issues, so your COI disclosure should be updated as changes occur. |
| Annually, by December 31 | Annual disclosures are required for all faculty, staff, and graduate students with assistantships, even if there is nothing to disclose or no changes are needed. |
| Prior to submitting a proposal | If you’re participating on a proposal, you’ll receive an email from DASH requesting that you review and confirm your COI disclosures are up-to-date. Updates must be completed before the proposal can be submitted to the sponsor. |
| At award intake | If you’re a named team member on a funded proposal, you’ll receive an email from DASH requesting that you review and confirm your COI disclosures are up-to-date. Updates must be completed before the award can be processed. |
| As required during the period of performance | ORSP can help you decipher these requirements in your award terms and conditions. |
WHY are COI disclosures important and how is ORSP involved in this process?
The COI disclosure process helps the University identify and manage conflicts between employees’ outside interests and their University responsibilities. Good stewardship of taxpayer funding for research, and preventing improper influence on that research, is a priority for the University of Tennessee. For individuals engaged in sponsored research, it is critical that UTC identify potential COIs as soon as possible to avoid potential legal, financial, and program implementation issues – for the institution as well as individual researchers. Note that disclosing an activity does not imply wrongdoing, nor does a disclosure mean that there is a conflict—it simply helps the university identify any perceived, potential, or actual conflicts that may need to be managed.
In collaboration with ORI, ORSP reviews the COI disclosures for all UT personnel named on a project before proposal submission, at award notice, and as required throughout the period of performance to ensure any/all applicable COIs have been disclosed to the sponsor.
WHERE Can I Go for Help or Questions?
| General questions about the COI policy or the disclosure process | DASH COI Hub |
| Questions about disclosures related to research or sponsored projects | [email protected] |