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.
Q. When will I receive a Conflict of Interest survey?
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.
Q. Who is required to disclose?
RUSH requires that individuals who meet the following criteria complete an annual online COI survey concerning their relationship and activities with non-RUSH entities:
- Full-time and part-time faculty staff, clinicians and physicians, students, fellows, trainees and interns who are engaged in research. Those who are considered key personnel on federally funded research must disclose before the issuance of federal funds
- Full-time and part-time faculty, clinicians and physicians regardless of tenure status
- Individuals whose position is classified as an administrator (director, assistant VP and above)
- Any individual who has significant input over the selection of outside vendors or providers of services, and
- Any individual (regardless of job class) who’s position holds a fiduciary obligation to RUSH whereby executes and/or directs or materially influences RUSH business decisions.
Q. What companies do I need to report?
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.
Q. What details will I be asked to disclose?
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.
Q. What if I did not receive payment, do I still need to disclose?
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.
Q. What if I receive payment in the form of equity/stock options/or other ownership interest worth zero dollars?
All forms of payment are required to be disclosed regardless of value. There is always the future potential for monetary gain.
Q. Who will review my disclosure?
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:
- The Clinical Conflict of Interest Committee (CCIC)
- The Conflict of Individual and Institutional Interest in Research Committee (COIIIR)
- The Institutional Conflict of Interest Committee (ICOI)
Q. What will happen if a COI committee determines that I have a conflict?
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.
Q. I have a change in one of my outside relationships, is it necessary to disclose the revision?
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).
Q. Can I update my disclosure after I submitted it?
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).
Q. Why can't I accept drug samples or coupons?
Sample medications and coupons are prohibited on or off RUSH campuses or clinics unless under special circumstances.
Q. How can I receive an exception for drug samples or coupons?
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.
- I have a disclosure question
- I cannot find my COI survey link
- I forgot my password to login
- I need help submitting my survey
- I need a copy of my last year’s disclosure
(Research) Protocol Specific COI (PSCOI) Disclosure
Q. How do I revise a previously submitted PSCOI disclosure?
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.
Q. Do I update a previously disclosed PSCOI disclosure by editing it?
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.
Education & Training
Q. Can my office or department receive training on the Conflict of Interest Policy?
Yes. Please contact the Conflict of Interest Office to set-up a training session.