Kuali Conflict of Interest

 The Kuali COI system will: 

• • Determine which conflict of interest regulations the researcher needs to complete, taking all the guesswork out of the historical paper forms
  • Send an email to the researcher with a direct link to Kuali COI embedded in the email
  • Allow researchers to assign specific support staff as “delegates” to assist

• How to Create your COI Disclosure
• Updating your COI Disclosure
• Revising your COI Disclosure
• How to Fully Submit Disclosure
• Adding a Delegate
• How Delegates assist with a Researcher
• How to Filter Projects
• How to Request Disclosure to be Returned
• How to Inactivate a Federal Financial Entity
• How to Add New Interest(s) to your Federal PHS Portfolio
• How to Add Multiple Attachments
• How to Answer Supplemental Questions
• How to Use Bulk Declaration for Federal Financial Entities
• How to Read Kuali COI Statuses in Kuali Research Records
• How to Check COI status in Kuali COI
• Description of Disclosure Statuses and Next Steps
• How to Update Previously Submitted 700U
• Kuali Research Unfunded Agreement COI Question
• Kuali Research Service Agreement COI Question
• NEW! How to Enter Financial Entities after REMS Integration
• NEW! How to Add Travel to PHS Federal COI Disclosure

All study team members are listed in Study Personnel in Kuali IRB application. Those Researcher’s with a potential conflict of interest* will need to mark “yes” under the conflict of interest question within Kuali IRB.

Potential Conflict of Interest Definition:

What should I do if I don’t know the Entity or Funding information when completing a 700-U COI disclosure in Kuali COI?

The State of California requires the Investigator to complete the Entity and Funding information on the 700-U COI disclosure form, in addition to answering questions about their relationship/interest(s) with the Entity. This includes the address and principle business of the entity, the amount of funding being proposed (estimated or actual), whether it is for initial funding or interim funding and the date of funding. Unfortunately, Kuali COI was not allowed to have these data elements auto-populated from the Kuali Research record. The Investigator can obtain the information by: 1) asking their fund manager or proposal creator, 2) googling the Entity (i.e., for address and principal business) or 3) reviewing the proposal record in Kuali Research (i.e., for the proposed funding amount and anticipated date of funding). The Investigator has the option to assign a “Delegate” in Kuali COI to complete the project specific information on their behalf. The “How to” instruction to add Delegates is on the COI Website.

What should I do if a project requiring a 700-U COI disclosure in Kuali COI was not funded?

700-U COI disclosure is required at time of proposal. Therefore, as soon as a non-federal proposal is created in Kuali Research or a manual project is created for a gift, Health Sciences Business Contracting service agreement, or human subject research, the Investigator will receive an email notification from Kuali COI to disclose. The 700-U COI disclosure will remain pending in Kuali COI until the Investigator completes the disclosure, even if the project is eventually not funded. If the Investigator logs in to Kuali COI and has pending 700-U COI disclosures for projects that were not funded, they must complete the disclosure as it should have been at time of proposal, i.e., with the amount of funding that was being proposed and the anticipated start date of the funding. Kuali COI requires all pending 700-U COI disclosures be completed prior to completing disclosures for federal projects. Therefore, if an Investigator receives an email notification from Kuali COI to update their disclosure for a federal project and there are pending 700-U disclosure forms, the Investigator will not be able to complete the federal disclosure until the 700-U disclosure(s) are completed.

What should I do if some of the information on a sponsored research project in Kuali COI was not accurate?

The accuracy of Proposal Development records in Kuali Research impacts the efficiency of many administrative processes including Kuali COI as a majority of the sponsored projects on an investigator’s dashboard in Kuali COI are directly from the data entered into Kuali Research based on various factors such as funding agencies, type of projects, role on a project, etc. These projects remain in Kuali COI until the sponsored projects are closed in Kuali Research.

If the investigator logs in to Kuali COI and sees projects pending disclosure with incorrect information such as incorrect project title, incorrect sponsor, etc., it is suggested that the investigator contacts the proposal initiator (i.e., departmental fund manager) when the record is still in proposal stage, or the applicable contract and grant officer (i.e., HSSPPO, OCGA, SIO OCGA, or OCTA) when the record is in institutional proposal stage or the award stage, to request a correction. Corrections made in Kuali Research will carry over to Kuali COI the next time the investigator logs into Kuali COI.

If you want to close your funded awards, please contact the Sponsored Projects Office (i.e., OCGA, SIO OCGA, or OCTA) to close your Kuali Research awards and then the record will no longer be active in Kuali COI. 

I received an email from Kuali COI to update my disclosure for a federal award, however there is a 700-U COI disclosure for a different project blocking me from updating my federal disclosure. What should I do?

Per State of California regulations, 700-U COI disclosures are required at time of proposal. As soon as a non-federal proposal is created in Kuali Research (KR), or a manual project is created for a gift, Health Sciences Business Contracting service agreement, or human subject research, the Investigator will receive an email notification from Kuali COI (KCOI) to disclose. The Investigator should complete the disclosure at that time. The 700-U COI disclosure will remain pending in KCOI until the Investigator completes the disclosure, even if the project is eventually not funded. If the Investigator logs in to KCOI and has a pending 700-U COI disclosure for a project that was not funded, they must complete the disclosure as it should have been at time of proposal, i.e., with the amount of funding that was being proposed and the anticipated start date of the funding. KCOI requires all pending 700-U COI disclosures be completed prior to completing disclosures for federal projects. Therefore, if an Investigator receives an email notification from Kuali COI to update their disclosure for a federal project and there are pending 700-U disclosure forms, the Investigator will not be able to complete the federal disclosure until the 700-U disclosure(s) are completed.

I do not have new research projects or change in interests. Why am I being asked to disclose in Kuali COI?

UC San Diego follows the Federal annual certification process since the launch of Kuali COI in January 2020.  While there may not be any new research projects or change in interests, Investigators with Federally funded (i.e., NIH, DOE, NSF, NASA, etc.) research are required to review, certify, and submit their Kuali COI portfolio on at least an annual basis.  Unlike the Non-Federal 700-U (i.e., for-profit and non-profit sponsors) disclosures, the Kuali COI Federal portfolio is not project based and must be certified in its entirety annually.