NU-RES and our partners, The Office of the General Counsel, the University Compliance Office and ITS offer Frequently Asked Questions & Answers related to reporting and managing potential and actual conflicts of commitment or conflicts of interest.
If you don’t see a relevant FAQ here please contact the NU-RES Help Center.
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A. General Conflict of Interest and/or Commitments
All benefits-eligible employees must report their actual and potential conflicts of interest and conflicts of commitment. In addition, individuals submit or receive extramural grants or contracts and who are responsible for the design, conduct or reporting of programmatic results must also report their conflicts of commitment or interest.
Please see specific questions on the Annual Conflict of Interest and Conflict of Commitment form. Individuals should report all outside employment, activities and/or financial interests in which personal or familial interests that conflict with or might compromise or appear to compromise the objectivity and integrity of your responsibilities to Northeastern.
You have an on-going duty to report conflicts and interests. In addition to completing each year’s annual disclosure, you will need to report any newly acquired or discovered interests within 30 days of discovery or acquisition.
Full disclosure of conflicts allows us to manage our responsibilities to our students and sponsors, as well as meet our legal and regulatory requirements. As importantly, your timely disclosures helps both you and the university identify potential or actual conflicts and effectively manage them.
In addition to the eCD website, please also see Northeastern’s Compliance Department’s website or contact a member of the Compliance Department.
If you have a question or concern regarding compliance, please speak with your supervise, unit or department head, faculty advise or to the senior manager or executive responsible for that specific compliance area, for example, the Director of Environmental Health and Safety.
Northeastern also encourages you to contact institutional office dedicated to supporting our culture of excellence:
- The University’s Ombuds
- Audit and Advisory Services
- Risk Services
- Human Resources Management
- Office of University Equity and Compliance
- Office of Institutional Diversity and Inclusion
The University also offers an anonymous and confidential Compliance Hotline for all members of the Northeastern community. The Compliance Hotline provides an alternative channel to communicate any concerns anonymously. The Compliance Hotline, which is accessible 24/7/365 via the web and telephone (1-855-350-9390), is managed by EthicsPoint.
Please contact Compliance if you have any questions or need clarification about any issues related to your disclosures.
Family includes spouse, spousal equivalent, children, parents, siblings, grandparents, parents-in-law, brothers-in-law, and sisters-in-law.
B. Annual Conflict of Interest and Commitment Disclosure
You will receive the annual email announcing the deadline for filing the disclosure report.
The reporting period for the Annual Disclosure is the previous calendar year, unless otherwise specified (e.g., for interests related to extramurally funded research and sponsored activities the definition is broader, all interests must be reported.
The deadline for completing the Annual Disclosure is stated in the annual disclosure email.
C. Conflict of Interest and/or Commitments related to Research & Sponsored Activities
All principal investigators and any other project personnel who are responsible for the design, conduct or reporting of results must report interests or commitments that reasonably appear related to their Institutional activities (e.g., research, teaching, public service, etc.). Please note: Reportable interests include those of the investigator and, if applicable, their spouse and/or dependent children.
You’ll need to complete Northeastern Compliance Department’s Annual Disclosure questionnaire and, in addition, depending on the extramural funding agency’s regulations, you may need to file, via NU-RES, supplemental information. Reportable interests are defined by the funding agency’s regulations or policies. Note: Reportable interests include those of the investigator and, if applicable, their spouse and/or dependent children.
Prior to submitting a proposal and, thereafter each year and, if during the year you have a newly discovered or acquired interest, within thirty days of discovery or acquisition. Please note: Once Northeastern’s Compliance Department’s Annual Disclosure cycle has closed, you can update your active disclosures at any time to reflect changes and corrections.
Timely filing creates a culture of excellent and is required under Northeastern’s policies; extramural agencies are also committed to providing transparency about the research, instructional or sponsored programs that they fund through the management of conflicts that could potentially bias or appear to bias findings or results. In addition, under the new procurement COI regulations funding agencies are also seeking to prevent unfair, direct benefit or financial gain by their grantees’ employees and subrecipients.
Often yes. Some extramural funding agencies require financial conflict of interest (fCOI) training, which must be updated at least every 4 years. Northeastern provides fCOI-compliant training via CITI. For more information please contact [email protected].
D. Using eCD
Northeastern’s electronic Conflict Disclosure (eCD) system.
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Last Updated on September 18, 2023