Terminology
COI Outside Interest Terminology
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Terms |
Definitions |
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Area Designee |
“Area Designee”, in this document, refers to the disclosee’s Chair or Supervisor, who is the first to review any relationships listed in a COI disclosure. |
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Annual Disclosure |
All Employees are required to complete an annual disclosure form regarding any employee identified potential, perceived or actual conflicts of interest or commitment, including all foreign affiliations and collaborations as outlined in this document, through the College’s electronic research administration software system (Cayuse). If the employee determines there is no potential, perceived or actual conflicts of interest, the employee shall indicate annually through the College’s electronic research administration software system (Cayuse). The disclosure will be routed as appropriate, and any conflicts will be managed by a conflict management plan |
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Conflict of Interest |
A Conflict of Interest exists where the personal, professional, financial or other interests of a trustee or employee potentially or actually diverge from, or appear to diverge from, their obligations to the College. |
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Reviewers of COIs |
Chair, Dean or Supervisor; Compliance Officer, COI Committee members and/or Vice Dean of Research |
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Employee (Disclosee) |
For the limited purpose of the Teachers College COI and Commitment Policy, Employee shall mean any faculty or staff who are categorized as full-time or scheduled to work twenty or more hours per week in one or more positions must disclose other employment or consulting work pursuant to this Policy. |
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Family or Household Member |
Includes the following: parents, step-parents, grandparents, guardians, spouses, children, grandchildren, uncles, aunts, nieces, nephews, brothers, sisters, or in-laws or a member of the immediate household of a person. Family or Household Member also includes a romantic partner, regardless of household status. |
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Foreign Entity |
Foreign Entity is any public or private entity organized under the laws of a country other than the United States and its territories, including, but not limited to, a foreign government, a foreign university, a foreign corporation, or an entity owned (in whole or in part) or controlled by a foreign government. |
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Foreign Talent Recruitment Program |
A program sponsored by a foreign entity, including foreign university, that compensates an individual in exchange for the agreement to transfer knowledge, experience or other intellectual assets to the foreign entity. |
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Teachers College Vendor |
Is any third party who contracts with the College to provide the College with goods or services, including, but not limited to, the vendors on this Vendor Schedule. |
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Manage |
Taking action to address a conflict by reducing, managing through a management plan or eliminating the conflict. |
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Management Plan |
A Management Plan is required when a conflict of interest(s) is identified. The content of Management Plans may vary depending on the nature of the conflict of interest and the level of conflict management required, and the conflict must be described in writing, specifying the actions to be taken to manage, reduce or eliminate the conflict, and defining the effective period of the plan. |
Research-Based Terminology
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Terms |
Definitions |
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Investigator |
According to the federal regulation, anyone who is responsible for the design, conduct, or reporting of research. In other words, it means the key personnel involved in the research. |
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Key Personnel |
The program director or principal investigator and other individuals who contribute to the scientific development or execution of a project in a substantive, measurable way, whether or not they request salaries or compensation. Key Personnel is sometimes referred to as Senior Personnel, and they are designated as such on a project. It also includes individuals who are likely to be authors on manuscripts or to present research findings at national conferences. It does not include administrative personnel or individuals who perform routine, pre-defined, or incidental tasks related to the project. Please note: Key personnel can be both internal TC employees but also external consultants, collaborators and even TC students who have been named as ‘Key Personnel.’ |
| PHS Research | Research funded by the Public Health Service of the US Department of Health and Human Services. It includes research funded by the following agencies: the National Institutes of Health (NIH), the Centers for Disease Control and Prevention, the Agency for Healthcare Research and Quality, the Food and Drug Administration, the Indian Health Service, the Health Resources and Services Administration, the Agency for Toxic Substances and Disease Registry, and the Substance Abuse and Mental Health Services Administration. It also includes the Office of the Assistant Secretary for Health, the Office of Global Affairs, and the Office of the Assistant Secretary for Preparedness and Response. |
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Financial Conflict of Interest in Research (FCOI) |
Involves situations in which an investigator (faculty, staff member, or student) has a significant financial interest that may compromise, or have the appearance of compromising, professional judgment in the design, conduct, or reporting of research. |
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Intellectual Property (IP) |
Includes issued patents, patent applications, copyrights, trademarks and other inventions. |
FAQs
COI Outside Interest FAQs
A conflict of interest arises when a situation or relationship (personal, professional, commercial, or financial) may compromise or appear to compromise a covered individual’s professional judgment in carrying out their institutional activities due to an external relationship or interest of the employee or their immediate family members. Such conflicts include any external relationships or interests that could:
- Compromise an employee’s or advisor’s judgment;
- Bias the nature or direction of scholarly research;
- Influence decisions or behaviors related to teaching, student affairs, appointments, promotions, use of the College’s resources or other College matters;
- Result in personal or immediate family member’s gain or advancement at the expense of the College
Conflicts of interest may also arise due to the mere appearance of a conflict. Our goal is for all employees and advisors to act with honesty, integrity, and in the best interests of the College while performing their duties, adhering to the highest ethical standards in research, education, professional, and fiscal conduct.
All College faculty, staff, and students in lead roles in research, (including full-time and part-time faculty and staff, visiting faculty, and all research team members) who are in a position to influence or commit University resources.
Research team members include the principal investigator and any other person who is responsible for the design, conduct or reporting of research.
A “Family or Household Member” includes parents, step-parents, grandparents, guardians, spouses, children, grandchildren, uncles, aunts, nieces, nephews, brothers, sisters, or in-laws or a member of the immediate household of a person. Family or Household Members also includes a romantic partner, regardless of household status.
Anyone who can impact decision-making or offer advice on purchasing, hiring, or anything involving the College’s funds or facilities.
An actual conflict of interest occurs when financial or other personal or professional considerations compromise an individual’s objectivity, professional judgment, integrity, or ability to perform their responsibilities to the College.
Perceived or potential conflicts of interest arise when a member of the TC community, their family member, or a close personal relation has financial interests, personal relationships, or professional associations with an outside individual or organization. In such cases, the individual's activities within the College could appear to be biased due to that interest or relationship.
Research Based FAQs
Conflicts of interest in research are present when Significant Financial Interest directly affect, or could appear to affect, the professional judgment of a researcher when designing, conducting, or reporting research.
Federal regulations require Teachers College to have policies to promote objectivity in sponsored work, including research for which Public Health Service (PHS) grants or cooperative agreements are sought, 42 CFR Part 50 Subpart F. The Academic and Research Conflict of Interest Policy can be viewed here [insert link]
Yes. Any person, regardless of title, position or employment status, whom the principal investigator identifies as ‘Senior Personnel’ (someone responsible for the purpose, design, conduct or reporting of research at, on behalf of, or in collaboration with the college is considered an investigator. They must complete COI training and disclose applicable financial interests.
Yes. Any person, regardless of title, position or employment status, whom the principal investigator identifies as ‘Senior Personnel’ (someone responsible for the purpose, design, conduct or reporting of research at, on behalf of, or in collaboration with the college is considered an investigator. They must complete COI training and disclose applicable financial interests.
Exemption to this policy is only in the instance where the external collaborator is part of a corresponding institution that maintains their own COI policy compliant with the federal government.
A financial conflict of interest (FCOI) exists where a researcher's outside interests (SFI’s) or activities could improperly affect, or give the appearance of affecting, the researcher's activities at Teachers College.
Examples of when SFI can be present when any of the following are received by an Investigator or their Immediate Family Member:
- Payments for services (consulting, lectures, advisory board payments, or honoraria);
- Equity interests, i.e. stocks, stock options, and other ownership interests; **
- Intellectual property rights (e.g., licenses and royalties);
- Donations (monetary, unrestricted funds, in-kind designated for research)
- Relationships and activities with foreign institutions and funding agencies
- All external professional activities.
- Federally funded Individuals are also required to disclose items such as sponsored or reimbursed travel and/or gifts and gratuities. These disclosures should be made using appropriate mechanisms and in accordance with relevant College policies.
- Travel: The system requires that sponsored travel be included in the disclosure, regardless of value. This does not, however, include travel included in a grant's budget or for travel funded by TC.
Exempted Sources: Only those payments from accredited institutions of higher education, U.S.-based government bodies, and research institutions will be exempted.
Yes. You must report all of your outside activities, even if you did not receive payment for them. Report any activities, relationships or interests that you have that were not coordinated or negotiated by TC.
No, these do not need to be disclosed.
Yes. You must update your disclosure throughout the year whenever your situation changes. This could occur due to either a change in your or your family’s financial interests or in the nature of your research. Some examples include:
- You receive a new financial interest;
- You conduct or plan to conduct new research that relates to an existing financial interest held by you or your family.
- If, at any time during the course of the year, you need to update your disclosure, log into Cayuse and select Amend Most Recent Annual Disclosure or Start New Annual Disclosure.
- Annually: Disclosure questionnaire must be completed annually;
- As needed: Revised disclosure questionnaire within 30 days whenever there is a significant change;
- Upon submission of a proposal: At the time of proposal submission, you will be prompted to identify any new SFI’s and those that pertain to the type of proposal and sponsor you are submitting to. You must update your Annual Disclosure questionnaire if there is something to report.
In addition to receiving a direct link via email to complete your annual disclosure, you will have full access to log onto Cayuse anytime. The questionnaire is housed on this grants management platform.
After your initial Designee reviews your disclosures, if a potential conflict is identified, the disclosure will be forwarded on to the Conflict of Interest Review Board for review. They will determine whether a significant financial interest related to the investigator/project Director of sponsored work constitutes an FCOI. Once an FCOI has been identified, the committee recommends a management plan and implementation mechanisms for monitoring plan.
Conflicts are reasonably expected to be disclosed when:
- The conflict has a direct and significant impact on the design, conduct or reporting of the sponsored project.
- The conflict can potentially undermine the college’s personnel's obligation to TC, the sponsor, research subjects, or students.
At any point, a sponsor may review TC and an investigator's records relating to sponsored research or contracted work to determine compliance with the corrective actions. If the sponsor determines that the conflict of interest has not been appropriately managed, reduced, or eliminated, this may terminate the agreement or suspend funding until the matter is resolved.
All investigators must complete a Disclosure to identify their financial interests, as applicable, no later than the 30th day of initial employment.
Teachers College requires mandatory Training for all “Investigators,” meaning “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 externally funded projects or proposed for such funding.” Training is required prior to engaging in research related to any externally funded project and at least every four years, and immediately when any of following conditions apply:
- The institution revises its financial conflicts of interest policies or procedures in any manner that affects the requirements of the investigators;
- a researcher is new to the institution; or
- when a researcher is found to be out of compliance with the regulations or with the institution’s financial conflicts of interest policy or management plan.
The goal of TC’s training modules is to introduce investigators not only to the technical requirements of the policy, but to inform them about the underlying ethical questions and to show how TC’s policies and procedures address those concerns within our own context, while remaining sensitive to the privacy of investigators.
Every 4 years.