The Dartmouth On-line Conflict of Interest system is different than the current paper-based annual process in several ways. The on-line system eliminates the need to complete and submit paper forms. Unlike the old process in which the PI certified on behalf of all key persons, the new process allows each Investigator or key person involved in a research project to complete the process him/herself via a simple and secure web interface. Another significant change is that the process will now require that Investigators answer questions in relation to a proposal/project submitted through OSP rather than disclosing all financial interests on an annual basis.
When a proposal for research funding is made to a funding agency, federal (NIH & NSF) regulation require each person responsible for the planning, conduct, design or reporting of the project disclose any financial conflicts of interest. Dartmouth College policy applies this standard to all externally funded research.
Information concerning financial interests related to your research projects will be submitted via a secure website at https://tower.dartmouth.edu/apex/groucho/f?p=260. You can access the system using your standard Dartmouth College login information. 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.
The Research COI system requires a Dartmouth Name Directory (DND) ID (ending in Dartmouth.edu). If you have a Dartmouth ID (most Geisel School of Medicine faculty do) but have forgotten the password, call the Dartmouth Help Desk at 603-646-2999 (or e-mail at help@mac.dartmouth.edu) and ask to have your DND password reset. If you know you do not have a DND name, you can request a Sponsored DND Account from Computing Services.
Read more about the Realm/Location drop down on the Web Authentication screen.
Each individual 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 (cut and paste) information common to multiple proposals so that it does not need to be entered de novo if there is overlap.
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.
Two initial questions ask whether you, your spouse, or a dependent child have a management position with the entity funding the project or a financial interest that might conflict with the research being proposed. If you have a conflicting 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, 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.
No, the previous process of submitting a paper-based annual disclosure for sponsored research has been eliminated.
The Research Conflict of Interest Application has a place to record disclosure updates. Updates may be made at any time.
You may be asked to report 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.
Review detailed instructions on confirming disclosures in progress.
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. Read more . . .
