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Disclosure Requirements

eDisclose Disclosure Requirements  

Who is required to disclose—Covered Individuals: 

Who is required to disclose to the Office of Outside Interests? 

When should Covered Individuals disclose?  

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OOI’s Disclosure Review Process

Once submitted via eDisclose, all disclosures are reviewed by OOI staff and/or the SOM Committee on Outside Interests. Disclosures determined to be higher-risk financial Interests and/or e higher-risk financial Interests and/or which pertains to certain IRB protocols are elevated to review by SOM’s Committee on Outside Interests or will be reviewed in consultation with the Deans of Research, as applicable. In each case, the relevant University official will determine whether such conflict is manageable or whether considerations of research integrity are such that the conflict can only be mitigated by terminating the relationship, activity, or financial Interest. If the University official determines that the Conflict of Interest cannot be managed, that decision shall be communicated to the Covered Individual in writing. 

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Review Outcome  

If the OI staff and/or the committee identifies a manageable conflict, OI staff will prepare a management plan, including conditions and/or limitations for the performance of the activity, which must be carried out in accordance with the terms of the management plan. Common conditions which appear in such management plans include, without limitation.:  

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Appeal process  

If a Covered Individual who holds a faculty appointment believes that a determination made under this policy in a specific case is not appropriate or is based on erroneous information, the Covered Individual submits an appeal letter through eDisclose, detailing the rationale for appeal. Consideration of the appeal will include a re-review of the arrangement by OOI staff, the COI Committee and/or the related Deans.