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Conflict of Interest (COI) Disclosures

All key personnel are required to submit a COI disclosure when receiving external funding to ensure CSUMB and its auxiliaries (UCorp) are in compliance with federal and state requirements.

About Conflict of Interest Disclosures

To better identify and mitigate all possible conflicts of interest (COI), CSUMB and axillaries now require COI disclosures for ALL funded projects. CSUMB is committed to upholding the highest ethical standards in research. By requiring COI disclosures for all investigators, we are able to proactively identify and mitigate any real or perceived conflicts that could compromise research objectivity, funding eligibility, or public trust. Having a transparent COI management program will further strengthen the credibility of our faculty-led research and ensures that external stakeholders, including funding agencies and the public, have confidence in the CSUMB’s research enterprise.

A COI Disclosure is needed prior to proposal submission, verified upon award, annually while funded, and ad hoc 30 days within a new financial interest identified and when new investigators join a funded project in accordance with the CSUMB Conflict of Interest Policy.  Subrecipients must also follow policies that comply with the funding agency’s regulations. COI training will be required per sponsor requirements and the CSUMB Conflict of Interest Policy for External Funding.

What requires COI review?

CSUMB requires Conflict of Interest (COI) disclosures for all funded projects, government and non-governmental via Cayuse. Disclosures are required before proposal submission, upon award, annually during award, and within 30 days of changes. All key personnel on a funded project must complete training and submit a disclosure via Cayuse Outside Interests.

More information on when COI review is required

Privately funded projects

For privately funded projects require filing a California Form 700-U and completing an online training module offered by the CSU that fulfills the State's training requirement. Prior to submitting a proposal and upon receiving an award, investigator’s will need to submit the 700-U form via Cayuse Outside Interests and complete CSUMB HR assigned training. This training is valid for (2) years.

Cayuse Outside Interests

Required COI training

Personnel on proposals to DOD, DOE, NASA, NIH, NSF, and USDA must complete COI training when completing their Outside Interests disclosure form via Cayuse. COI training is valid for 4 years and offered via CITI Program. For private funding that is reported via the 700U form, you will be assigned required state training directly from CSUMB Human Resources.

COI Training via CITI Program

COI Review Process

All COI disclosures will now be processed via Cayuse Outside Interests.

Step 1: Review what requires COI disclosure and the COI Policy

Review information about what requires COI review and review the CSUMB Conflict of Interest Policy for External Funding.

Step 2: Complete COI training via CITI

COI Training via CITI Program

Personnel on proposals to DOD, DOE, NASA, NIH, NSF, and USDA must complete COI training when completing their Outside Interests disclosure form via Cayuse. COI training is valid for 4 years and offered via CITI Program.

NOTE: For private funding that is reported via the 700-U form, you will be assigned required state training directly from CSUMB Human Resources. 

Step 3: Start your Cayuse Outside Interests disclosure

Start a Research Based Disclosure

An OI disclosure form is created for Personnel listed in a Cayuse SP proposal or award when it is submitted to the Sponsored Programs Office (SPO). 

Additionally, you can create you our Research Based Disclosure from your Profile in Cayuse.

  1. Start your disclosure and indicate if you are reporting due to private/non-governmental funds or governmental funds. NOTE: For state or Chancellor's Office funds, check governmental in the Cayuse OI disclosure form. 
  2. For non-governmental funds you will be asked to provide the sponsor’s name and complete a 700-U form and attach it to your disclosure.
  3. For governmental funds, you will be asked to report financial conflicts per federal guidance. 
  4. Answer questions about foreign relationships and non-financial relationships related to the funded project.
  5. Be sure to complete every question and certify your disclosure.

Manage Your Disclosure

  • Disclosures will need to be maintained for life of an award which may include annual disclosures to confirm relationships.
  • Any changes to your financial and non-financial relationships should be reported within 30 days.

Step 4: Review Process and Resolution

Review Process

  1. Unsubmitted – Your disclosure is incomplete and has not been submitted for review.
  2. Under Review – Your disclosure has been assigned for review.
  3. Returned – More information is needed about a relationship and you must respond to the COI office.
  4. Disclosure Complete - Your disclosure requirement has been fulfilled.

Resolutions

  • No COI Determined – No relationships disclosed pose a direct conflict.
  • COI determined and managed – The COI will be in touch to discuss a management plan.
  • COI determined and unmanageable – The COI cannot be managed or you find the management plan disagreeable.

Need help?

Email us at coi@csumb.edu

Who must disclose?

Any personnel on a funded project who are responsible for the design, conduct or reporting of the research. This would include senior and key personnel and all others who contribute to the scientific development or execution and reporting of a project in a substantive, measurable way whether or not they request or receive salary or compensation.

When must disclosure be made?

Personnel must disclose any changes or new potential conflicts within thirty (30) days of acquiring or discovering them.

Non-governmental Sponsors – 700U State of California requirement

The State of California requires principal investigators to disclose financial interests with non-governmental entities from which funding is requested to ensure public employees are not personally benefitting at the expense of the public interest. Reference Fair Political Practices Commission  Title 2, Division 6, Section 18755.

Governmental sponsors - Awards received directly from the designated sponsors or as a pass-thru award

In compliance with federal regulations, investigators and anyone responsible for the design, conduct, and reporting of research are required to disclose significant financial interests (SFIs) that could be reasonably expected to bias the design, conduct, or reporting of the project. The disclosure requirement also applies to any member of the Investigator’s immediate family, specifically, any dependent children, spouse or domestic partner. 

NOTE: For State of California or Chancellor's Office funds, check "Governmental" in the Cayuse OI disclosure form. 

The following are SFIs which must be disclosed:

  • Any income or other payment for services related to your institutional responsibilities (e.g., research, research consultation, teaching, professional practice, expert witness, advisory board membership, etc.) received within the previous 12 months which exceeds $5,000, including services completed during Sabbatical or Difference of Pay.
  • Publicly traded equity owned or acquired within the previous 12 months in any Publicly Traded Entity, the value of which exceeds $5,000. This includes any stock, stock options, or other ownership interest.
  • Any payments received for any intellectual property rights and interests (e.g., patents, copyrights, trademarks, assigned or licensed to a party other than the Regents and excluding academic or scholarly works) within the previous 12 months which exceeds $5,000.
  • Travel reimbursement or payment by any entity within the past 12 months the value of which is equal to or exceeds $5,000. Payments from federal, state or local governments, U.S. institutions of higher education, or a research institute, academic medical center or hospital affiliated with U.S. institutions of higher education are excluded.

Foreign Support

CSUMB and auxiliaries requires disclosure of any foreign support and relationships to better identify possible conflicts of interest, real or reasonably perceived by others, which when disclosed to the University can further improve credibility and trust with sponsors, the research community, and within our local community. Investigators must disclose all foreign financial interests to identify any potential malign foreign influence concerns.

Project-based Interests

Investigators must disclose any other interests, including non-financial, related to institutional responsibilities and external funding that could present an actual or potential conflict of interest. CSUMB and auxiliaries intend to avoid any real or apparent conflict of interest while performing project-based activities. It is up to CSUMB and auxiliaries to evaluate the existence of any real or apparent conflicts of interest and resolve them accordingly. Conflicts of interest include activities where investigators use their positions for purposes that are, or give the appearance of being, motivated by a desire for private gain for themselves or others, such as those with whom they have family, business or other ties.

Identification of relationships that may be recognized as a perceived or actual conflict of interest can further improve credibility and trust with sponsors, the research community, and within our local community. The University recognizes disclosure as a key factor in protecting one's reputation and career from potentially embarrassing or harmful allegations of misconduct.

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Michelle Burgett-Moreno

Research Integrity and Compliance Officer