A conflict of interest describes a situation in which a person is or appears to be at risk of acting in a biased way for having a personal or financial interest with other people, groups, or businesses. A conflict of interest exists when relationships develop, the ability to act in the best interests of a person or group could be affected as the individual may be influenced or benefit financially. If you are in any doubt as to whether a conflict may exist, please seek advice from your supervisor in the first instance or contact the COI Office at 312-942-5303.
For detailed information on what is prohibited activity, please click here.
Please also refer to the COI related policies page for more information, limitations and exceptions.
The COI survey is distributed each year in July after the fiscal year has ended. Individuals required to complete an annual COI survey will receive an email with their personal link to complete a disclosure. Any non-RUSH activity that occurred between the months of July 1st-June 30th, no matter the value, should be disclosed annually. However, at any time your activities should change, RUSH requires your submitted disclosure be updated within thirty days (30) of that revision.
RUSH requires that individuals who meet the following criteria complete an annual online COI survey concerning their relationship and activities with non-RUSH entities:
Typically
Any for-profit enterprise that develops, manufactures, sells, or distributes drugs or medical devices or other goods and/or services to the health care industry, including but not limited to, pharmaceutical companies, medical device manufacturers, laboratories, imaging companies, sales organizations, banks, auditing firms, law firms, insurance companies and consulting firms.
For each company, commercial entity, or organization that you list, you will be directed to provide the details regarding your relationship, activity or involvement, time dedicated to the activity, your direct payment or other forms of compensation / benefits, accepted from that company, commercial entity or organization for the previous fiscal year (July-June), including outside activities that you anticipate to occur during the next fiscal year.
Yes. All outside interests and relationships performed by you or your immediate family members during the previous fiscal year (July 1st- June 30th) must be disclosed even if you did not receive payment, including activities that you anticipate to occur during the next 12 months should be disclosed.
All forms of payment are required to be disclosed regardless of value. There is always the future potential for monetary gain.
Based on your role with RUSH, your disclosure may be reviewed and evaluated for potential conflicts of interest and commitment from one or more of the following three COI committees:
If a situation has the appearance of a COI, the COI committee will determine the significance of the activity and issue a management plan which will include the appropriate steps to manage it. Conflicts are managed on a case-by-case basis in order to reduce or eliminate the conflict, as needed.
Yes. It is necessary to notify the Conflict of Interest Office (COI Office) when there is a change in one of your outside relationships, within thirty days (30) of that revision, by updating your disclosure (s) in the RUSH Research Portal (RRP).
Yes. Send an e-mail to the COI Office to have it reopened. If you need to update a protocol specific COI disclosure related to a research study go into the RRP to edit your disclosure within the related Master Project (MP).
Sample medications and coupons are prohibited on or off RUSH campuses or clinics unless under special circumstances.
To request an exception, the prescriber or coupon issuer must complete an Exception Request form and submit it to the COI Office. To obtain an Exception Request form, contact the COI Office and send an email to: Rush_Conflict_Of_Interest_Survey@rush.edu. All request will be routed to the Chief Medical Officer for review.
Note: If your request is approved, approved requests will expire three (3) years after the approval date. To receive an extension, the prescriber or coupon issuer will need to complete another request at that time for reevaluation.
For any of the issues listed below, please visit the COI Technical Assistance page or contact the COI Office by e-mail.
If you have made an error or did not complete a previously submitted protocol specific disclosure: Select the COI disclosure you want to revise by ‘clicking’ on it in the Master Project Main Page under the COI Module (“My COI”). This will bring you to the ‘start page’ of your previous COI disclosure. At the top of the left hand toolbar ‘click’ on ‘Edit COI’. This will open your previously submitted disclosure for you to revise.
No. You create a new COI disclosure within the COI module found on the Master Project main page. Answer question #3 –‘Yes’ this is an update to a previous disclosure. Provide all the information detailing your relationship with the outside entity with the updated/new information.
Yes. Please contact the Conflict of Interest Office to set-up a training session.