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To contact the COI officer, please e-mail coi-help@mit.edu.
Can an investigator do a new disclosure without having completed the training?
Yes. The training is on policy, some of which they would need to know in order to know what to disclose, but yes, the training and the COI disclosure are separate and are separately tracked.
Do PI’s need to know the proposal number in order to access certification or COI?
The notification email link will bring them directly to the correct screen in Kuali Coeus for certification. At the end of the Certification questions, they will be prompted with a link to the COI site if a full COI is required. If they leave the COI module and have to reenter, they can go in again through “MyCOI” where they choose from a list. The PI would then need to know which one to choose.
Does all foreign travel need to be disclosed?
All travel sponsored or reimbursed by a foreign organization must be disclosed, regardless of the type of organization sponsoring the travel.
Foreign (and other) travel sponsored or reimbursed by any of the following need not be disclosed:
- MIT
- U.S. Federal, state or local governmental agencies
- U.S. Institutes of higher education
- U.S. Research institutes affiliated with Institutes of higher education
- U.S. Academic teaching hospitals and medical centers
Does the aggregator need to exit proposal before the PI can go in to do the certification or COI disclosure?
No, because the link in the certification notification does not send the recipient to the KC Proposal but to a separate Certification Questionnaire. Completed certifications will update even if the aggregator has a lock on the KC Proposal. COI Disclosures are in Coeus Lite, not in the KC proposal.
Does travel disclosure apply to NIH Investigators only?
At this time the travel disclosure requirement applies to NIH and other PHS agency Investigators and Key Persons, plus Investigators with awards from Foundations that invoke the PHS COI policy.
How should Subrecipient PIs/Consortium PI’s etc be entered in proposals?
They should be entered as Key Persons with the role “Subaward Investigator” in order for Coeus to handle them correctly and not require certification or COI (which should be handled at their own institution).
How should Subrecipient PIs/Consortium PI’s etc be entered in proposals?
They should be entered as Key Persons with the role “Subaward Investigator” in order for Kuali Coeus to handle them correctly and not require certification or COI (which should be handled at their own institution).
I generally pay for travel to professional meetings out of my own pocket, in order to maximize the funding available from each of my grants to pay students. Do I need to file travel disclosures for such trips?
The NIH travel disclosure policy does not include your own travel which you pay for yourself and for which you are not reimbursed. It is only reimbursed or sponsored travel that requires reporting.
I have been instructed to do a disclosure, however, the Master Disclosure (or Initial disclosure) button is inactive. What should I do?
At a certain point during the process of creating and submitting a disclosure for review, you may find buttons on the MY COI menu screen are inactive (grayed out). If you started a disclosure but exited before completing it you may be able to locate it using the Other Disclosures in Progress button under the Revise heading.
If the NOA simply says change in “Key Persons” needs approval, do you have to go to NIH for approval?
Only if the Key Person is actually named in the award would approval be required per NIH policy.