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.
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 on the dedicated website.
