April 30 Deadline
All faculty and staff engaged in research at the University of Iowa are required to complete an “Annual Disclosure of Outside Professional Activities and Interests” via the eCOI online disclosure portal by April 30 each year. This includes anyone named as key personnel on either a HawkIRB application or a sponsored projects routing form for externally funded research. To ensure that external activities are conducted in a manner consistent with institutional and public values, institutional policies require that University employees avoid improper conflicts, and otherwise disclose activities for review and management.
Implications of the Annual Disclosure Requirements with Human Subjects Research
- Employees who have not completed the annual requirement will receive reminder emails from the UI Compliance and Qualifications system on April 1, April 25, and April 30. Supervisors and Compliance Administrators will be copied on the final two notifications.
- Principal investigators will be unable to route a proposal routing form through the Division of Sponsored Programs until they have completed the certification.
- The eResearch application, HawkIRB, will flag research team members identified as key personnel as noncompliant if they have not completed the annual disclosure by May 1. This flag in the HawkIRB system will prevent the Principal Investigator (PI) from submitting any new projects, modifications or continuing reviews to the IRB until the annual disclosure of the research team member is complete. An incomplete annual disclosure could result the team member being removed from the HawkIRB application and halt their participation in any research related activities.
- In addition to the annual “flag” for the renewal of the annual disclosure, any new researchers and key personnel must complete the financial disclosure in the electronic conflict of interest (eCOI) system before they can be added to a HawkIRB application.
Who should disclose
HawkIRB automatically defines the PI and any research team members with a faculty appointment as “key personnel.” Other key personnel designations are for anyone involved in the design, conduct, and/or the reporting of the research. These roles are specified because they provide opportunities for the introduction of bias into the research. If you are unsure if this applies to you, check with the PI of any studies in which you are a research team member.
What to disclose
Disclosures should be submitted for any outside activities and interests that are related to an employee’s role or area of expertise at the University. This includes activities and interests of spouses and dependent children, and relationships with both domestic and foreign entities.
International Engagement
The University requires all researchers to disclose activities with foreign governments and institutions of higher education, such as presenting or teaching. These disclosures should also include any form of payments, stipends, honoraria, and remunerations. Full and timely disclosure regarding research support and conflicts of interest is essential to ensure compliance with federal regulations and sponsor requirements. Failure to disclose this information can have significant fiscal and regulatory consequences, impacting both the individual PI and the institution.
Institutional Policies
For additional information on annual disclosure and conflict of interest, please see the following:
- Policy on Conflicts of Interest in Research,
- Policy on Conflict of Interest in the Workplace,
- Policy on Conflicts of Commitment,
- Policy on Conflicts of Interest in Employment (Nepotism),
- Policy on Institutional Conflict of Interest in Human Subjects Research,
- UI Health Care Conflicts of Interest Policy, and
- Accreditation requirements for Continuing Medical Education.
After April 30, employees may add new, review or edit previously submitted reports directly using https://ecoi.uiowa.edu.