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What to Disclose

RUSH requires that individuals who meet the following criteria complete an annual web-based Conflict of Interest (COI) disclosure, aka COI survey concerning relationships and activities with non-RUSH entities and all activities related to innovation and technology development:

Who Should Disclose


  • 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.

Disclosure Examples

Some examples of situations where a conflict of interest may or may not exist may include an individual’s immediate family member(s) who are involved in one or more of the following activities, regardless of payment or value received:

  • Participation in outside speaking engagements
  • Consulting
  • Equity Ownership - Investments in drug, device or biotechnology companies
  • Ownership of testing facilities or treatment centers or other healthcare related organizations
  • Received reimbursement incentives (including sponsored or reimbursed travel)
  • Business courtesies (e.g., gratuities, gifts, loans, services, entertainment, meals, or other favor)
  • Acceptance of drug samples and/or coupons
  • Intellectual property interests (e.g., patents (including patents pending), licenses, copyrights, royalties)
  • Accepted training funds for use of medical devices
  • Affiliation with a foreign government entity or foreign institute of higher education
  • Foreign government or foreign institute of higher education grants and all remuneration

Please refer to the COI Policy (OP-0359), Research Policy (CC-RC-0008) and Vendor Guidelines for more information.