Tulane's Policy on Conflicts of Commitment and Interest
Annual disclosure of outside interests and commitments:
Tulane University’s Conflict of Commitment and Interest Policy requires all full-time/part-time compensated Faculty/Staff members, as well as Investigators/Key Personnel (regardless of affiliation) participating in research, to submit the Conflicts of Commitment and Interest Disclosure of Information Form (COI Disclosure Form) on an annual basis.
Updates to an existing COI Disclosure Form:
If at any time after submitting the COI Disclosure Form you have a material modification, acquisition or discovery of any new leadership role, secondary commitment or financial interest, you must promptly, but no later than thirty days after the modification, acquisition or discovery, submit an updated COI Disclosure Form.
Platform for disclosure of outside interests and commitments:
Complete, submit and, when applicable, update your COI Disclosure Form on the dedicated Cayuse website.
Information for Non-Tulane affiliates (external collaborators):
Please complete this form if you are an external collaborator, i.e., not an employee of Tulane but involved in a Tulane research project and need to complete the Tulane COI Disclosure Form. The form will result in the creation of your profile in Cayuse, the COI disclosure platform. You will receive a Cayuse-generated email prompting you to complete your COI Disclosure Form.
Disclosure vs. Conflict:
The disclosure is of financial interests, secondary commitments and/or leadership roles (collectively “outside interests and commitments”). The Conflict of Interest Committee (COI Committee) determines whether any outside interest or commitment could give rise or actually gives rise to a conflict of interest and/or conflict of commitment. If the COI Committee determines that a conflict of commitment or conflict of interest exists, then the COI Committee will endeavor to work with the Faculty or Staff member, or Investigator (regardless of role or position) to manage, reduce or eliminate the conflict of interest or conflict of commitment.
There is only one instance when an outside interest is by definition a conflict of interest. Any research financial interest that exceeds $10,000 and is related to human subjects research is a per se conflict of interest.
Additional Information for Healthcare Practitioners and Researchers:
- Reporting consistency with CMS Open Payments: If you are a physician, physician assistant, nurse practitioner, clinical nurse specialist, certified registered nurse anesthetist or anesthesiologist assistant, or certified nurse-midwife, the University requires that your disclosure of any payments made to you by drug and medical device companies be consistent with the information reported in CMS Open Payments.
Medical Residents and Students:
If you meet the policy definition of “Investigator”, you are required to submit a COI Disclosure Form. Please complete this form first. The form will result in the creation of your profile in Cayuse, the COI disclosure platform. You will then receive a Cayuse-generated email prompting you to complete your COI Disclosure Form.
FAQs and Training Resources:
Video and text training on how to complete and submit the form is available here and here.
Public Health Service (DHHS, NIH, FDA, CDC, HRSA, etc.) FCOI Information and Requirements
- Training on Conflict of Interest policy and regulation: Collaborative Institutional Training Initiative (CITI) located at www.citiprogram.org/
**Instructions for accessing the CITI training site
- PHS COI regulation information can be found at the NIH FCOI website
- Informative Frequently Asked Questions on the PHS regulation can be found at the NIH FAQs on FCOI for PHS Investigators
- FCOI Digest: Brief description of key elements of the PHS Conflict of Interest Regulations. This document is distributed at the time of application for PHS funding to ensure that investigators are informed of the PHS COI requirements.
- Checklist for PHS Investigators: Checklist for COI compliance at the proposal, award and project duration stages of PHS funded research
- Requests for information on FCOIs reported to PHS agencies must be submitted in writing to:
Tulane University
Office of the General Counsel
Attn: Administrative Compliance Specialist
300 Gibson Hall, 6823 St. Charles Avenue
New Orleans, LA 70118-5698
