Conflict of Interest

Disclosure Form

Albert Einstein College of Medicine (Einstein) ensures objectivity, balance, transparency, and scientific rigor in all academic activities. Individuals employed as faculty by Einstein, otherwise employed and appointed to the Einstein faculty, or otherwise employed and identified as “Investigator” on an Einstein sponsored research protocol or grant, (“Obligated Disclosers”) are required to disclose financial interests or other relationships that may create (or create the appearance of) a conflict of interest, and are also required to help resolve such conflicts. 

Information Pertaining to Conflict of Interest Disclosure 

Disclosure: Obligated Disclosers must report external Financial Interests (FI) of any dollar value, and Relationships with External Entities, at the time of appointment or hiring, in relations to certain “Events.” (See below for definitions and exclusions).

  • Financial Interests (FI) include salary or remuneration for services regardless of dollar value.
  • Disclosure also must include the Significant Financial Interests (SFI) of a Related Party (spouse, domestic partner, or dependent child).
  • Disclosure must be complete, timely and truthful.

Timeliness: 

  • An updated disclosure must be submitted within thirty (30) days of acquiring new FI, SFI or External Relationship.  
  • A COI disclosure on file must be updated if it is more than six (6) months old at the time of review in response to an “Event.”

Please be familiar with the following definitions and gather the relevant financial documents you may need to complete the form before initiating or updating your conflict of Interest disclosure:

Events Requiring Disclosure Updating and Review:  

  • Acquisition of new FI, SFI  or External Relationship;
  • Submission of a grant proposal (once a priority score, “just in time” notice, or notice of award has been received. COI review must be completed before the expenditure of any grant funds;
  • Submission of a human subjects research proposal;
  • Submission of an animal research protocol;
  • Filing for a patent or clinical trial agreement.

External Relationships Requiring Disclosure: Any leadership, decision-making, officer or other fiduciary role, in a corporate entity or organization external to Einstein.

Significant Financial Interests (SFI) (Federal regulations require disclosure of SFI pertinent to federally funded research):

  • With regard to a publicly traded entity, SFI exists if the value of any remuneration (salary or payment for services) from the entity in the twelve months preceding disclosure, and the value of any ownership interest in the entity as of the date of disclosure, when aggregated, exceeds $5,000.
  • With regard to a non-traded entity, SFI exists if the value of any remuneration (salary or payment for services) entity in the twelve months preceding disclosure, when aggregated, exceeds $5,000, or when the investigator or related party holds ANY equity interest.
  • Intellectual property rights and interests (e.g. patents, copyrights).
  • Disclosure must be updated within 30 days if any new remuneration from or ownership interest in an entity results in an aggregated value of $5,000 or more.

FI and SFI Exclusions Include: 

  • Income from investment vehicles (mutual funds/retirement accounts) as long as the individual does no5t directly control investment decisions made in these vehicles;
  • Income from seminars, lectures, or teaching engagements sponsored by federal, state, of local government agency, an institution of higher education, an academic teaching hospital, a medical center, or a research institute that is affiliated with an institution of higher education; or
  • Income from service on advisory committees or review panels for a federal, state of local government agency, institution of higher education, an academic teaching hospital, a medical center, or a research institute that is affiliated with an institution of higher education.

Travel: Individuals also must disclose within thirty (30) days the occurrence of any travel related to their institutional responsibilities that is reimbursed or sponsored (i.e. paid on behalf of the individual and not reimbursed  so that the exact monetary value may not be readily available) by a not-excluded entity.

See Einstein Comprehensive COI Policy for additional information: New Comprehensive Conflict of Interest Policy 

Conflict of Interest Disclosure Form (On campus) 

Off-Campus users: contact COI@einstein.yu.edu for remote access*

*New users: Please go to the link above and attempt to log-on. If you do not know your username credentials, please attempt using an e-mail address. If your profile is not registered, you will be prompted to create a new user profile. You will receive a reply within 72 business hours, including instructions on how to log-in to the COI web system along with your log-in credentials. Replies from the COI e-mail account occur during business hours only. 


(3/29/2017)

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