COMPLIANCE CHATTER

Special Announcement

On March 1, 2024, the Office of the Vice President for Research (OVPR) will be launching a revised FCOI disclosure e-form with a new look, revised question format, improved smart-form branching, and changes to how interests/activities are disclosed. This will modernize the FCOI form functionality, as well as standardize and harmonize the University’s FCOI disclosures.

Investigators will see improved functionality, such as: pop-up error messages to highlight missing items for greater clarity, embedded definitions to assist with understanding, and smart-form branching that tailors questions based on individual responses.

Applicability and Timing

Investigators (individuals identified as responsible for the design, conduct or reporting of research) at UConn Storrs and Regional campuses who are subject to the FCOI in Research Policy are still required to complete an FCOI disclosure annually and within 30 days of the acquisition or discovery of any new significant financial interests (SFIs). 

Automated Reminders

Investigators will continue to receive automated email reminders from the InfoEd External Interests/FCOI system in advance of their annual FCOI disclosure submission due date. No action is needed until receipt of the annual reminder, unless an updated disclosure submission is requested by Sponsored Programs staff or a Department Administrator.

Access

The new form is still accessed electronically through InfoEd.

Training

Required FCOI training continues to be incorporated into the disclosure form.

New Screening Page

The Screening page of the current form is organized as YES/NO questions by type of entity (i.e., public entity, non-public entity, and non-profit entity), followed by questions about royalties and travel. In the new form, the Screening page will be reorganized as YES/NO questions by Type of SFI (e.g., Remuneration, Equity or Other Ownership Interest, Travel, Other Financial Interests, etc.). Some responses will branch to additional questions. If a YES requires an SFI disclosure, an additional Entities page will be presented for investigators to provide the required disclosure information. Investigators should continue to refer to the training and policy to ensure all required SFIs are disclosed

Non-Compensated Appointments and Other Affiliations

A new screening question will ask investigators to disclose any non-compensated appointments and/or other affiliations. These are roles where investigators (and/or their immediate family) serve in a personal or representative capacity for an entity related to the investigator's institutional responsibilities. This disclosure facilitates a review of University research in relation to such appointments for consideration of potential research financial conflicts of interest. In the previous form, investigators were not asked to disclose non-compensated appointments.



Types of non-paid appointments/affiliations that will need to be disclosed:

If your role(s) do not fall under these categories, the form will also allow you to select “Other” and type in your role(s).

Please note, a non-paid appointment for service to a scholarly society is not required to be disclosed on the new form.

Patents

A revised screening question will ask investigators to disclose if they (and/or their immediate family) are an inventor/creator (or owner) of any intellectual property (IP) possibly related to their institutional responsibilities such as patents, software, or computer programs, whether or not they receive royalties. This includes patents owned by the University (UConn and UConn Health). This disclosure facilitates a review of investigators' University research in relation to such patents, for consideration of potential research financial conflicts of interest. In the previous form, investigators disclosed IP only when they received income from intellectual property rights paid by an entity other than the University of Connecticut.

Other Financial Interests

A new screening question (and Other Interests section of the form) will provide investigators an opportunity to report any other actual or potential conflicts related to their institutional responsibilities. A free-text box provides an option to write-in any additional relevant information.

Entities Page

The e-form section where investigators disclose interests will have a new look and new method for SFI disclosure entry. All interests, except for qualifying travel, will be entered by entity name on one page.

Selecting Entity Names From a Standardized List

Investigators will select the entity name from a list, instead of entering as free-text. If a company does not appear in the list, investigators will select "Not Found" and enter the name manually.

Selecting Significant Financial Interest (SFI) Type From a Drop-Down List

After selecting an entity, investigators will disclose each type of qualifying activity/interest they (and/or their immediate family: spouse and dependent children) have with that entity by selecting the category from a drop-down list. Investigators can enter multiple activity/interest types under one entity. 

Selecting a Range for the Value of Interests

Those who have SFIs with a dollar value of $5,000 or more from a single entity will report the value of those interests in ranges from a drop-down list, rather than exact amounts.

Responding to Research-Related Screening Questions for Each Entity

The e-form now incorporates preliminary research-focused screening questions about each entity to help identify possible research financial conflicts of interest.  

Disclosing Non-Public Entity Equity or Other Ownership Interests

Investigators are still required to disclose interests held with a faculty-affiliated company and/or any other ownership interests (regardless of value) in a non-public entity that is possibly related to their institutional responsibilities. Investigators will report the percentage ownership held by selecting the range from a drop-down list, rather than the exact value of the ownership interest. There will also be an optional field for reporting number of shares, if known.

For topical questions related to the FCOI in Research policy/process and disclosure requirements, email fcoi@uconn.edu.

For technical Issues with Disclosures in InfoEd, contact the eRA Help Desk:

Mon-Fri, 8:00 AM – 4:30 PM

Era-support@uconn.edu

860-486-7944