The Dartmouth On-line Financial Interest Disclosure system has been updated to account for changes to Federal regulations applicable to Investigators who currently have or are applying for funding from the Public Health Service (PHS). The PHS is a division of the US Department of Health and Human Services, and includes the NIH, the CDC, the FDA, and many other institutes and agencies.
You will be asked upon entry to the system if you receive or are applying to receive PHS funding. If no, you will notice only minor updates to the system. If yes, the system has been updated to allow for disclosure as required by the new PHS regulations. The biggest changes to the system are as follows:
Annual Disclosure: Each person who is responsible for the design, conduct or reporting of PHS research will be asked to enter the system and submit an "Annual Disclosure" of all significant financial interests related to any of their institutional responsibilities (and not just related to a specific project or proposal). Investigators will need to update the information given in their Annual Disclosures at least annually, and within 30 days of acquiring a new significant financial interest.
Travel Disclosure: PHS-funded investigators must also disclose the occurrence of travel that is sponsored or reimbursed by an outside entity. After entering the system and answering "Yes" to the PHS funding question, you will find a separate dashboard for the disclosure of travel information. Please note that there will be a field to indicate the person who will be travelling if different from the person entering in the information, which will allow administrative personnel to enter this information for their principals.
PHS Certification: The Project-specific Disclosure dashboard will function in nearly the same way as the online system always has – Investigators will have the opportunity to enter the system at the time that they are submitting a proposal and disclose significant financial interests which are related to a specific project. They will also be asked to quickly review previously made disclosures and certify that they are complete and up to date.
Before a proposal for research funding is made to a funding agency, federal (NIH & NSF) regulations require each person responsible for the design, conduct or reporting of the project disclose any significant financial interests. Dartmouth College policy applies this standard to all externally funded research.
Information concerning significant financial interests will be submitted via a secure website at http://tower.dartmouth.edu/apex/groucho/f?p=260. You can access the system using your Dartmouth College NetID.
When you enter the system, you will be if you receive or are applying to receive PHS funding.
For non-PHS Investigators, the system will direct you to a dashboard page which will show a summary of your proposals and any disclosures that have been submitted related to those proposals. If you have not yet submitted a disclosure for a specific proposal, you will click on the "Create New Disclosure" link and the system will guide you to two basic questions. In answering these questions, you will indicate whether or not you (or a spouse/partner or dependent child) have a management position with the sponsor or a financial interest related to the project. If the answers are no, once you submit your responses you are done. If an answer is yes, you will be asked to provide more detail and certify your responses to complete the process.
For PHS Investigators, the system will direct you to a page where you may choose to submit an Annual Disclosure, a Project-specific Disclosure, or a Travel Disclosure, as described in the answer to Question 1 above.
The Research COI system requires a Dartmouth College NetID. If you have a Dartmouth NetID (most Geisel School of Medicine faculty do) but have forgotten the password, call the Geisel Help Desk at 603-650-1600 (or e-mail at Geisel.Computing.Support@Dartmouth.edu) and ask to have your NetID password reset. If you know you do not have a NetID, you can request a Sponsored DND Account from Computing Services.
A non-PHS Investigator who is key personnel on a proposal will be required to complete the on-line questions prior to final approval and submission of the proposal to the sponsor. Since the process is project-specific, you will be asked to complete the process for each proposal in which you are listed as a key person. The website will allow you to transfer (copy forward) information common to multiple proposals so that it does not need to be entered de novo if there is overlap.
A PHS Investigator will be required to complete the on-line questions (1) Annually, (2) within 30 days of acquiring a new significant financial interest or taking sponsored or reimbursed travel and (3) prior to final approval and submission of a proposal.
In most cases, department grant managers will be initiating the proposal review process. Since COI reporting is part of the proposal review and approval process, department grant managers will remind each key person of the requirement. However, you will be able to access the system at any time and each person who is listed as key personnel is responsible for submission of information regardless of whether or not you are reminded by your grant manager.
In addition, PHS Investigators will be notified centrally by the Office of Sponsored Projects via email that their Annual Disclosure is due.
Two initial questions ask whether you, your spouse, or a dependent child have a management position with an entity related to your Professional Activities or a significant financial interest that might affect or be affected by your Professional Activities.
For PHS Investigators, "Professional Activities" means any of your institutional responsibilities, which may include research, teaching, administrative activities, consulting work done on behalf of Dartmouth or Dartmouth-Hitchcock, and/or participation in panels such as the IRB or Data and Safety Monitoring Board.
For Non-PHS Investigators, "Professional Activities" means their involvement in the research being proposed.
If you have a significant financial interest, a series of follow-up questions ask you to describe the source of the financial interest and your relationship to that source.
You need to complete the Research COI process for all proposals submitted through the Office of Sponsored Projects. If the project involves human subjects a separate COI process specific to human subject protection may also be required that accompanies an application for CPHS review.
COI information is available to the Vice Provost for Research, the Director of OSP, the Assistant Provost for Compliance, the Conflict of Interest Officer, and the OSP IS Manager (for report writing purposes). If your disclosure is referred to the Conflict of Interest Committee, members of that Committee (all faculty or officers of the College and Dartmouth Hitchcock Medical Center) will also see your disclosure.
The Dartmouth On-line COI system is project-based. The potential for conflicts of interest arise when there is both sponsored funding for a project and an investigator who has a related significant financial interest. One project might involve a conflict of interest because an investigator has an investment in the funding source, while another project - for the same investigator - might have no conflict if the funding source were different. Thus, the determination of the existence of a conflict is based on the convergence of two factors - the project's funding and the investigator's financial interests.
The Research Conflict of Interest Application has a place to record disclosure updates. Updates may be made at any time.
If you are a PHS Investigator, updates may be made at any time by re-submitting an Annual Disclosure and submitting new or edited questionnaires about your significant financial interests.
You may be asked to report other financial interests in relation to your non-research professional responsibilities (e.g. in relation to DHMC clinical duties or continuing medical education). Currently, these processes are separate from the on-line research reporting system. Reporting interests related to sponsored research does not eliminate or substitute for other institutional processes related to financial interests including disclosures to DHMC for clinical or other duties.
Most often, this happens because a researcher will complete a questionnaire, but fails to "confirm" the disclosure. Because we offer users the ability to save a disclosure that is not complete (maybe you want to think about your responses, or have to look something up on your tax return), we need a way for you tell us when a disclosure is complete. This is what confirmation does. When you save a questionnaire, you are automatically brought to a screen that asks if you want to confirm your responses, and tells you this step is necessary for a disclosure to be complete. If you managed to miss this step, we have instructions on how to find your incomplete disclosure and complete this step.
If you log on to the COI application and do not see your project, you should check with your department grant administrator. It is possible that your project is in the process of being recorded in the proposal system and will appear shortly. If not, you will be directed to create a temporary project, a process you can access from the My Research Projects page of the COI application.
Last Updated: 2/21/14