Frequently Asked Questions About the Annual Conflict of Interest Process

Each year, the Compliance Committee asks select employees to file a Disclosure Form annually through a web-based COI Application [url:https://www.bu.edu/coi] indicating whether they have conflict. Employees who are required to file are prompted to do so via an email from Compliance Services during the spring semester. These disclosures are collected pursuant to the University’s Conflict of Interest Policy. The process is managed by the Compliance Services Office on behalf of the BU’s Compliance Committee.

“Selected Employees” are chosen by members of the Compliance Committee based on their title, job duties, and employment grade in SAP (the employment information system). Decisions about employees included in the population are based on things like supervisory responsibilities and purchasing authority, among other criteria. You can reach out to the Compliance Services Office for details on how and why you were selected as a filer.

In accordance with the BU Conflict of Interest Policy,  only (1) family conflicts, (2) business or financial relationships, and (3) Service in organizations where an employee serves as a director, officer, employee or other agent at the University’s request or as the University’s designated representative must be reported on the annual disclosure form. See the definitions section below for specific information about how these three conflicts are defined.

If the organization you serve on at the University’s request or as a University representative ALSO does business or has a Business or Financial Relationship with the University, you should report the relationship as a Financial Conflict on your Disclosure Form – but note your role as BU’s representative or that your service is because BU requested it. Note that the Business or Financial Relationship does not need to be an exchange of money, as it is defined under Policy as including “the sale or acquisition of goods, property, or services; or the commitment of resources to a common venture.”

Any employee with a member of their immediate family employed by the University should include this family member on their disclosure, even if the family member is a student-employee.

No. A business or financial relationship does not include attending Boston University as a student.

The Compliance Services Office reviews and logs all disclosures to determine if the reported conflict needs further management. If it does need further management, the Compliance Service Office will work with Human Resources and/or the Conflict Monitor (typically a supervisor) to ensure that the relationship is managed appropriately. For example, if a child works in the same department as a parent, there will be follow-up to ensure that the child/relative is not supervised by the parent.

Yes. Any research conflict reporting done through the Research Support/Research Compliance Office is separate and apart from the disclosure requirements pursuant to the University’s Conflict of Interest Policy. Instructions on how to submit a research COI disclosure for an unfunded or internally funded IRB project can be found on the Office of Research’s website here: https://www.bu.edu/research/ethics-compliance/conflicts-of-interest/huron-coi-instructions-page/#IRB.

The University has developed a chart to assist you in understanding how the research conflict disclosures are different from the Annual Conflict of interest process managed by the Compliance Services Office.

Yes. BMC’s Conflict of Interest Disclosure Process is separate from the University’s from BU’s disclosure requirements pursuant to the University’s Conflict of Interest Policy.

No. For the purposes of the Conflict of Interest Policy and the annual disclosure process, you are not required to identify organizations in which you serve in your personal capacity. Organizations that must be reported are ones in which you serve as a director, officer, employee, or other agent at the University’s request or as the University’s designated representative. Our COI Policy only requires reporting for relationships that are at the behest of BU.

However, note that if you are a faculty member subject to the Faculty Handbook, you must submit an External & International Activity Report (EIAR) to your Dean in accordance with the Conflict of Commitment Policy, and that report might require you report certain organizations as external activity.

The relationship would need to be reported as a business or financial relationship on your form if  you have “A significant interest” which includes “service as a trustee, director, partner, or management-level employee; the actual or beneficial ownership of more than 5% of the entity; or a compensation arrangement that is dependent upon a business or financial relationship with the University.”

If the relationship does not rise to the level of a significant relationship, you could still choose to report the relationship to ensure that the University is on notice. You should also be aware that if you are receiving any compensation from the organization or they are reimbursing you for travel, this relationship would fall under BU’s Solicitation and Acceptance of Personal Gifts and Relationships with Vendors Policy, and you would need prior approval before accepting such compensation from them pursuant to that Policy.

To update your form, you’ll take the same steps you did to file the first time. You log in through the web application [URL: https://www.bu.edu/coi] and then when you get to the welcome screen, you will select the Amend button instead of the View button. The Amend button appears in the bottom right hand corner of the welcome screen. See the picture below for reference.

When you submit your amended disclosure, your old disclosure will be overwritten with your new Disclosure Form, and you will receive a new confirmation number. You will be able to amend your form until the disclosure period ends on September 1.

All BU employees  (including those not included in the Annual Disclosure Process) are subject to the Conflict of Interest Policy and must disclose any time when they have a financial, family, or organizational conflict. If you try to resubmit your form (as described in the question and answer directly above) and the system does not let you file again, you can use a paper form. The paper COI form should be filled out and sent to the Compliance Services Office if a conflict arises through the course of the year that must be disclosed.