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Conflict of Interest (COI) FAQs

Conflict of Interest Reporting


What forms are filed?

The Conflict of Interest forms in use are approved by the Council of Presidents of the Kansas Regents institutions. The same forms are used at all Regents' institutions. The forms consist of Form A Declaration and Form B Disclosure.

Form A
Form A asks individuals to declare whether they, their spouse, or other household members have any substantial interest or time commitment related to their own research or educational activities. The standard of "conflict" is whether an independent observer would conclude the appearance of undue influence or a conflict of interest. The purpose of Form A is to identify whether there is a potential conflict. The majority of employees have no substantial interests to disclose, and Declaration Form A completes their report.

From B
Individuals who declare that they have substantial interests or time commitments as defined by the criteria on Form A must disclose details on Form B. The purpose of Form B is to identify under what conditions a conflict Management Plan may be needed. The purpose of a management plan is to outline how the conflict will be eliminated or minimized and monitored.

For example, if an individual responds that she has ownership interests that meet the thresholds given on Form A, she will be directed to list them in the corresponding section on Form B. The unit head and COI committee then determine whether a management plan is called for.

Who is required to file COI reports?

Kansas Board of Regents and the KU-Lawrence policies require conflict of interest reporting by
  • all full-time faculty and unclassified staff and
  • any part-time faculty and staff who are engaged in the design, conduct, or reporting of research, or who have a potential conflict

How often is filing required?

Reports must be filed:
  • on employment
  • annually, and
  • on an ad hoc basis
Ad hoc reports: Regents policy requires ad hoc reporting of any new situations that may raise questions about conflict of interest. These activities should be reported as soon as they become known. If the issue pertains to federally funded research, government regulations require that the newly-disclosed conflict be managed, reduced, or eliminated, at least on an interim basis, within sixty (60) days of its identification.

How many signatures are required on the COI forms?

Most forms will require three signatures:
  • the employee
  • the chair, director, or unit head; and
  • the dean or vice provost the unit reports to
Some administrators require only one signature in addition to their own:
  • Chairs, directors, and unit heads obtain the signature of their dean or vice provost.
  • Deans and vice provosts obtain the signature of the Provost or Chancellor.

What does the supervisor's signature indicate?

"Accepted" as used in the COI forms indicates that the supervisor who countersigns has reviewed the form and agrees to the best of his or her knowledge that the filer is in compliance with the COI policy.

What are the consequences of failing to comply?

Failure to comply with reporting and disclosure requirements for conflict of interest and time commitments will have one of the following consequences:
  1. Individuals will not be allowed to submit internal or external grant applications until they have complied.
  2. Failure to comply may result in disciplinary action.

Definitions and Frequently Asked Questions

What is a Conflict of Interest?

"Conflict of interest" refers to situations in which financial or managerial interests or time commitments may compromise, or have the appearance of compromising, scientific judgment, integrity of research data, fulfillment of professional duties, or the safety and welfare of research volunteers. A conflict of interest depends on the situation and not on the character or actions of the individual.

Conflicts can be individual or institutional in nature. Individual conflict of interest may be associated with financial incentives in research, business ownership, consulting, intellectual property development, outside employment, and commitment to external organizations. Institutional conflict of interest arises from financial interests of the university or senior officials that might color the review, approval, or monitoring of research.

It is important to note that potential conflicts frequently arise in university settings, often as part of desirable and legitimate professional development. Activities such as consulting and commercialization of technologies represent the fulfillment of the university's mission to translate scientific discoveries into beneficial products and services. KU encourages interactions that promote public benefit while ensuring the integrity with which those activities are accomplished.

Standards for reporting: financial and managerial interests of
  • ownership (includes inventorship);
  • compensation;
  • office; or
  • fees and commissions which exceed a defined threshold and which an independent observer could conclude might influence or conflict with research/educational activities.
All of the above may include, but are not limited to, consulting fees, stock holdings, equity interests, outside professional positions, outside professional salary, and loans.

Applies to: Faculty and unclassified staff. adjunct appointments, and their spouses and other household members.

Overseen by: Office of Research and Graduate Studies. The Conflict of Interest Committee reviews disclosures and management plans, and recommends approval of management plans. Departments oversee implementation of management plans. The Office of Research and Graduate Studies confirms compliance status of researchers for grant submissions.

Governing Policies: Kansas Board of Regents, federal policies, and KU Lawrence Supplemental Policies

What is a Conflict of Time Commitment?

Conflict of time commitment exists whenever a faculty or staff member's external activities exceed reasonable time limits or whenever an unclassified staff or faculty member's primary professional responsibility is not to the institution.
Standards for reporting:External time commitments should be reported if they relate to university responsibilities. These include consulting, outside employment, public service, pro bono work, or service as an officer in an external entity.

Applies to: Faculty and unclassified staff.

Overseen by: Office of Research and Graduate Studies. Conflict of time is reported with conflict of interest. Disclosures of time commitments are reviewed by the COI Committee. Conflicts of time are mediated by the department and Office of the Provost, in accordance with the Consulting Policy.

Governing Policies: Kansas Board of Regents, federal policies, and KU Lawrence Supplemental Policies

I've reported my consulting activities on my Conflict of Interest report. Does this satisfy the reporting and approval requirements of the KU Consulting Policy?

No. Approval for consulting is a separate process which is overseen by the Office of the Provost. The Regents and federal Conflict of Interest reporting requirements in no way change the existing Regents or KU Consulting Policies or the responsibility of each faculty or unclassified staff member to follow reporting and approval procedures regarding consulting.
Standards for reporting: Information and forms for approval of consulting and other outside work are available on the policies and resources page of the Office of the Provost website.

Applies to: Faculty and unclassified staff.

Overseen by: The Office of the Provost.

Governing Policies: Kansas Board of Regents, federal policies, and KU Lawrence Supplemental Policies

My grant application form contains a conflict of interest certification. If I've certified that I have no conflict of interest on a grant proposal, do I still need to submit a Conflict of Interest report?

Yes. Individuals who submit grant applications must certify that they understand and have complied with the Conflict of Interest policies. Your signature on the certification form indicates that your financial interests and time commitments have not changed since your most recent conflict of interest report. Certification for grant submission is not a substitute for Conflict of Interest reporting.

What is the difference between the State of Kansas Statement of Substantial Interests and Board of Regents Conflict of Interest Reporting?

For many years, state employees with certain kinds of responsibilities have been required to file an annual State of Kansas Statement of Substantial Interests (KS SSI) in accordance with the laws administered by the Kansas Secretary of State. More information about the KS SSI is available on the Kansas Governmental Ethics Commission Web site.

In 2006, the Kansas Legislature approved a change in the scope of state employees required to file the KS SSI. As a result, many KU faculty were required to file the statement for the first time in the spring of 2006. These are two separate reporting requirements. Having filed a KS SSI does not change faculty or staff obligation to file a COI declaration at least annually.

Questions? Please contact:
William Sharp
785-864-7430 | wsharp@ku.edu
Director | Research Integrity

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Susan MacNally
785-864-4148 | sumac@ku.edu
Compliance Coordinator | Research Integrity