Fall 2020 Annual COI Disclosure Update
Coming September 2020, the way Annual Conflict of Interest Disclosures are submitted will change. Parts of the AIR disclosure system will be replaced with our new Niner Research system. If you are required to disclose annually, please look out for an email inviting you to submit your Annual Conflict of Interest Disclosure.
Note for researchers: you will continue to use AIR to submit research-related Conflict of Interest Disclosures. However, in the Spring of 2021 Niner Research is expected to expand to cover these disclosures, too. This is great news! In the future, the Annual COI disclosure and the research-related COI disclosures will harmonize into one and will be updatable. This will greatly reduce the number of disclosures researchers are required to submit.
Faculty and non-faculty EHRA staff are encouraged to engage in outside relationships with commercial companies, the nonprofit sector, and federal and state governments if the activities are consistent with the mission of the University. Such partnerships in support of the University’s three-fold mission of teaching, research, and service are encouraged when they produce mutual benefits to participants as well as benefits to society. Facilitating the transfer of technology to improve the health and productivity of society is an important goal of cooperative university-industry and faculty-industry relationships.
The number and complexity of relationships between universities and public and private organizations have grown substantially in recent years, which have increased the concern about conflicts of interest and commitment. All members of the University community are expected to avoid conflicts of interest and conflicts of commitment that have the potential to compromise their objectivity in carrying out their institutional responsibilities.
The purpose of UNC Charlotte’s Policy on Conflicts of Interest and Commitment is to provide guidelines for those relationships that will help to ensure academic integrity and ensure compliance with federal and state requirements.
UNC Charlotte affiliated personnel
University Policy 101.24, Conflicts of Interest and Commitment, applies to:
- All full-time, part-time and adjunct members of the faculty
- All non-faculty EHRA staff
- Designated SHRA staff (see COI Policy for details)
- Research personnel involved in the design, conduct, or reporting of a funded research project, contract, sub-contract, or other agreement.
Disclosures must include the Financial Interests of immediate family members (i.e., spouse and dependent children).
Individuals responsible for the design, conduct, or reporting of a Public Health Service (PHS) funded research project are also required to disclose sponsored travel and paid authorships.
Subrecipients and Independent Contractors
Individuals meeting the definition of Investigator (i.e. responsible for the design, conduct, or reporting of a funded research project) may include non-university personnel, such as subcontractor employees, collaborators, or consultants/independent contractors. If the project is NSF or PHS funded and the subrecipient’s home institution does not have a compliant COI Policy, then that subrecipient must agree in writing to comply with the UNC Charlotte COI Policy. Independent Contractors that meet the definition of Investigator are always subject to UNC Charlotte’s COI Policy.
Note: Phase I Small Business Innovation Research (SBIR) or Phase I Small Business Technology Transfer Research (STTR) grants are excluded from the PHS COI regulations. However, Phases II & III are not excluded from the PHS COI regulations.
- Publicly Traded Companies
- Ownership of stock, options, etc. from any entity during the preceding 12 months, for you and your family members that appears to be related to your institutional responsibilities.
- Note: Investments in which you do not directly control investment decisions, such as mutual funds or retirement accounts, do not need to be disclosed.
- Privately Held or Nonprofit Companies
- Any ownership or equity interest from any entity whose stock is not publicly traded, by you and your family members that appears to be related to your institutional responsibilities.
- Other Financial Interests
- Any secondary employment that is related to your professional responsibilities at the university. Examples would include: private consulting, serving on a board of directors, speaking engagement, etc. Note: This reporting is in addition to the separate prior notification and approval requirements for SHRA and EHRA employees.
- Royalties from textbooks or other scholarly works
- Intellectual Property Rights
- Intellectual Property (IP) in which you or your family members, have an existing or proposed licensing interest.
- IP rights held (or in negotiation) for a pending or issued patent in which you or your family members are listed as inventors.
- Excluding unlicensed IP held by UNC Charlotte.
- External Roles
- Paid or unpaid positions of influence, by you or your family members, with an entity in which the interests of the entity appear related to your institutional responsibilities (i.e. CEO, President, Scientific Advisory Board member, etc.).
- Student Involvement or Supervisory Roles
- Situations in which an activity could create a potential conflict of interest or commitment with respect to a faculty member’s mentorship responsibility.
- Textbook or course material selection that results in receipt of royalties or other potential financial conflicts of interest.
- Sponsored Travel (PHS only)
- Any reimbursed or sponsored travel whose aggregate value paid or reimbursed by any single entity meets or exceeds $5,000 in the prior twelve months, except travel that is reimbursed or sponsored by a Federal, state, or local government agency, an institution of higher education, an academic teaching hospital, a medical center, or a research institute that is affiliated with an institution of higher education.
- Annually (October 1st deadline)
- At the time of research project proposal
- At each new increment of research project funding
- Upon assuming new University Employment Responsibilities
- Within thirty (30) days of discovering or acquiring any financial interests for which disclosure is required
- Prior to engaging in External Professional Activities for Pay (EPAP)
PLEASE NOTE: Grant proposals may not be submitted and projects will not receive final approval until disclosure forms are received from ALL personnel listed on the project. Funding will not be released until any potential conflicts have been reviewed and managed, and training has been completed.
Niner Research is the University’s new research management system; all Annual Conflict of Interest disclosures and External Professional Activity for Pay (EPAP) submissions are submitted in Niner Research. Starting in 2020, UNC Charlotte will begin implementing additional modules in the Niner Research management system.Annual Conflict of Interest Disclosure
- Annual Conflict of Interest disclosures are required from all covered employees in Niner Research.
- In addition to the Annual disclosure, covered employees must update their Annual Conflict of Interest disclosure within 30 days of any changes.
- AIR, the previous system, is available only for proposal-related disclosures. This is a self-service form. See below.
- Covered employees include all EHRA staff, all faculty members (including part-time and adjunct faculty), and select SHRA roles.
- This disclosure requirement applies to individuals on leave from the University if that leave is funded at least partially from University sources. Email COIManger@uncc.edu for additional information.
- The deadline for submitting an Annual COI disclosure is October 1. Invitations to participate in the Annual COI disclosure campaign will be sent out on approximately September 1 of each year. A new form is released yearly; early submissions may require an additional submission if the new form is not utilized.
- External Professional Activities for Pay (EPAP) are also disclosed in Niner Research.
- The Niner Research COI disclosure form integrates the EPAP form; in the Pre-screening page, eligible staff and faculty should carefully review question 4 to determine if an EPAP is present.
- EHRA staff and faculty whose FTE is greater than or equal to 0.75 are subject to the External Professional Activities of Faculty and Other Professional Staff policy (UP 102.1) and must submit an EPAP form prior to participation.
- SHRA staff should review the Secondary Employment Employees Subject to the State Human Resources Act policy (UP 103.3).
- EPAP submissions must be submitted no less than 10 days prior to participation in the activity.
- A member of the discloser’s leadership will review and either approve or not approve the EPAP(s) submitted. The integrated Annual COI disclosure will then be sent to the COI Manager for review.
Proposal related Conflict of Interest disclosures ONLY are submitted in AIR at this time. If you are key personnel on a sponsored project, you will be sent an email with a unique link to submit your disclosure. This is NOT a self-service form. Contact COImanager@uncc.edu or your research administrator for more information. With the integration of additional modules in Niner research this process will change.
Resources & Contact Information
Disclosure and Training Resources
- Niner Research instructional resources
- Niner Research access portal
- COI Training in AIR (for key personnel only)
Policies and Guidelines
- University Policy 102.1, External Professional Activities of Faculty and Other Professional Staff Exempt from the State Personnel Act
- University Policy 101.24, Conflicts of Interest and Commitment (Updated May 2016)
- Procedures Supplemental to University Policy 101.24
- University Policy 204, Textbooks and Instructional Materials
- UNC Policy Manual, Chapter 300.2.2, Conflict of Interest and Commitment
- Guidelines on Implementing the UNC Conflict of Interest and Commitment Policy
Public Health Service (PHS) 2011 Revised Regulation resources
- NIH Summary of Major Changes to the 1995 Regulations
- NIH Frequently Asked Questions (FAQs)
- List of agencies following PHS COI rule
Other useful information
- Notes on COI
- NSF COI Policies for Grantee’s
- Financial Relationships and Interests in Researching Human Subjects
Sherry Loyd – Associate Director for Research Protections and Integrity and COI Manager, 704-687-8270