The Berman Institute has joined the University’s divisions as a reporting entity for disclosures of professional commitment and conflicts of interest, requiring disclosures of these activities during the annual processes as well as throughout the year. Because Berman Institute faculty have tenure line appointments in many different divisions, the Berman Institute processes for disclosure will be slightly different than in other units, as follows:
Faculty who have tenure line appointments in other divisions should continue to submit disclosures through those divisions. The new requirement is for faculty to alert BI by email as soon as new disclosures are submitted. The email should be sent to Julia Chill ([email protected]) and the subject line should include “COI,” your last name, “initial” for the initial disclosure, and the eDisclose number (“COI, Smith, initial, 123456”). Emails also should be sent when you receive an outcome or management plan (“COI, Smith, outcome, 123456”).
The BI Director and Director of Finance & Administration will review new disclosures and comments will be shared with your divisional COI staff.
Faculty and fellows who have appointments solely in BI should submit all disclosures through the BI as described below. Disclosures will be reviewed for completeness and compliance with notifications by email to check your eDisclose account for the outcome. The outcome will list the conditions or management plan associated with the review and any required changes to your relationship with the entity. Faculty may accept or appeal the outcome.
When You Need to Disclose
- Prior to undertaking an outside commitment
- Prior to submission of an application for PHS support on which you are an investigator
- Within 30 days of acquiring or discovering a financial interest related to your institutional responsibilities
- Whenever a disclosed interest or activity changes (e.g., amount or type of remuneration, type of service, time commitment) or ends
- During the Annual Certification period (to ensure that disclosures are accurate and up-to-date)