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:
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