Conflict of Interest and Commitment

The Institution has updated the policy on Conflict of Interest and Conflict of Commitment as of September 2020. Following this update in Fall 2020, the WHOI COI/COC Annual disclosures will be made in January 2021 and thereafter through the new Streamlyne Research Administration program, which also incorporates information on the status of COI training required for Principal Investigators and other members of the administration to enable them to recognize potential conflicts of interest or commitment. The 2023 Annual Disclosure must be submitted through Streamlyne by January 31, 2024. COI training if required must be completed by February 28, 2024.

Instructions on How to Enter an Annual COI/COC Disclosure in Streamlyne are available in the Related Files on this page. If you have not completed COI training through the CITI Program or are unsure how to do so please visit: https://generalcounsel.whoi.edu/conflict-of-interest-and-commitment/conflict-of-interest-training where instructions and the registration link are available. If you have questions, please email coi@whoi.edu

Completing the Disclosure

Activity Disclosure in Streamlyne due: January 31, 2024

As established under the COI/COC Policy all individuals at the Institution are required to disclose annually their outside professional activities and significant financial interest in entities that could be related to funded research or work at WHOI. Updates are required within 30 days for changes and new activities and financial interests. Failure to complete required disclosures will delay proposal submission to an agency and may affect establishment of awards.

Who must fill out the Conflict of Interest Disclosure Form: All personnel at WHOI -- including scientific, technical, administrative staff and all other employees, post-doctoral fellows/ investigators/ scholars, and anyone with a WHOI appointment. Only MIT-WHOI JP students; WHOI Guest Students; and non-employees with a WHOI appointment who have received less than $5,000 from WHOI in the past year (e.g., MIT faculty with a WHOI faculty appointment, Guest Investigators, and Visiting Scholars) are excepted from this policy.

Additionally, anyone who is named on a proposal must file a disclosure—this includes MIT-WHOI JP students, WHOI Guest Students, and non-employees with a WHOI appointment.

Individuals report on 2023 activities and significant financial interests in the Annual Disclosure due by January 31, 2024 that can be found as follows:

• WHOI employees and others with WHOI email and LDAP will make disclosures through Streamlyne. Disclosure link for WHOI employees, Emeriti and affiliates with WHOI email and LDAP.

Conflict of Interest Training

Conflict of Interest training is required of all PIs and many staff members (see Training List) every 4 years. The training is on-line, and you must first register at the training site. The results of your training will be stored in a database and are reflected in your Streamlyne disclosure at the Reporter tab. If you do not see your CITI training in the Reporter section of the Streamlyne disclosure, you may need to add your CITI Learner ID to your Streamlyne record. Please contact your Department/Center Administrator or email to coi@whoi.edu for instructions.

Instructions to register for COI training

1. WHOI employees and individuals with WHOI email and LDAP password
2. Individuals without WHOI email and LDAP password

Public Health Services Financial Conflict of Interest

Individuals planning to submit proposals to or who have ongoing research funds from any Public Health Services Agency (e.g. NIH, CDC) will complete additional questions within the Streamlyne disclosure. This process replaces the PHS Financial Conflict of Interest Form (FCOI), which will no longer be used.

Relevant links:

• Public Health Services Agency financial disclosure and training requirements: See Policies & Procedures and Conflict of Interest for Public Health Service Agencies (NIH, CDC, FDA)