Why am I assigned the task of reviewing disclosures for my whole area?
What are the reviewer’s responsibilities?
What is the OnBase system?
How much of my time will it take to review disclosures?
When am I expected to accomplish the reviews?
What resources are available if I am uncertain how to proceed with a disclosure?
What are members required to disclose?
Do I have to read every disclosure submitted for my assigned area?
What if a member believes they have not been assigned the appropriate reviewer?
What happens if not all members submit a disclosure within the deadline?
The conflict of interest policy, approved in September 2009, identifies the reviewers for this process. You may assign a designee for all or portions of your area to assist in the reviews. Please contact the COI Program Manager in the Office of General Counsel at firstname.lastname@example.org or 631-6411 to arrange.
Reviewers are key components of this process. Reviewers are responsible for:
- Emphasizing the annual disclosure requirement to their faculty/staff
- Ensuring submitted disclosures are complete
- Assigning a conflict of interest category when information is submitted
- Developing a Management Plan for managing, reducing or eliminating any conflicts
OnBase is a documentation and routing system that facilitates the conflict of interest disclosure process. Access is only granted to reviewers , those responsible for administering the system, the University Conflicts Committee and the Office of Research.
The Conflict of Interest Application (COIA) is a web-based system developed in-house which allows all members access to respond to the disclosure questions. This system then forwards the responses to the OnBase system to proceed through the disclosure process.
While the number of members in your area who are required to submit disclosures may be large, it is only the disclosures with “yes” responses that will require in-depth review. The OnBase system separates the disclosures that have provided any “yes” responses into a departmental review queue. It is possible that none or only a few disclosures will appear in this queue. This queue is where you’ll spend time evaluating any information that has been disclosed.
Disclosures with “no” responses to all questions will be sent to a “no conflicts queue.” Since there is no additional information to read, it is not necessary to pull up each disclosure in this queue. You will be asked, however, to approve these disclosures as complete. If you feel that a member is missing any information on the disclosure, you may send it back to be re-submitted.
During the annual disclosure process, members will have 15 days to submit a disclosure. Reviewers are asked to complete reviews within 15 days after submission. You will receive advanced notice of the annual disclosure deadline and be expected to check into OnBase periodically to perform reviews.
Throughout the rest of the year, members are asked to update a disclosure when any change in status affects their conflict of interest disclosure. You will receive an e-mail notice when an updated disclosure is received in OnBase and in need of review.
The conflict of interest website provides several resources:
- A narrative or power point presentation providing an overview of the process
- A two-page navigation guide for using OnBase
- Checklist for evaluating disclosures
- Menu templates to use when developing a management plan
At any time in this process you may contact the COI Program Manager in the Office of General Counsel at email@example.com or 631-6411 for further assistance.
All individuals at the University who are in a position to influence or commit University resources are required to disclose any of the following that relate to their work at the University, and that could reasonably appear to others to relate to their work:
- Significant financial interests in a third party entity
- Management positions with a third-party entity
- Professional or personal relationships
- Non-University income from any activities that involve students, staff or the use of Notre Dame facilities
You may assign a designee to assist with this process. Additionally, disclosures submitted which contain all “no” responses do not need to be read individually.
Members should contact the COI Program Manager in the Office of General Counsel at firstname.lastname@example.org or 631-6411 PRIOR to submitting their disclosure.
Members will receive an e-mail notification of the approaching deadline. The Office of General Counsel will also be providing a list of members who did not submit disclosures within the expected time frame and asking for your assistance in following up with those individuals.