COI Disclosure or COA Request: What's the difference?

COI: All University employees submit Conflict of Interest (COI) disclosures in InfoEd to report financial interests, business relationships and payments from external entities that might create actual or perceived conflicts of interest, or to certify that they have none. Disclosures are made on an annual basis and must be updated within 30 days of acquiring a new reportable financial interest or business relationship. These disclosures are retrospective, they report interests and activities that have already occurred.

COA: Full time faculty, both academic and administrative, who plan to engage in a compensated outside professional activity (COA), such as consulting, must provide advance notification to, and receive written approval from, their supervisor or supervisor's designee. COA requests are also submitted in InfoEd. COA requests route to the employee's supervisor or designee for review and approval. If the reviewer has a concern that the COA may result in a conflict of interest, the request may be routed to the COI Designated Official for review before an approval decision is made. Employees should not engage in the COA prior to an approval decision being recorded in InfoEd.

Who do I contact for help?

If you have questions about conflicts of interest or questions regarding the COI Disclosure forms, please contact the COI Designated Official, Michele Dondanville, at (775) 784-6360 (available from 8 a.m. to 5 p.m. Monday through Friday) or by email at

Why am I receiving COI email notifications?

  1. You received an email notification during the fall COI Disclosure Campaign because you are a University employee. The email is to let you know it is time to certify (for new) or recertify (for existing) an annual COI disclosure form.
  2. You will continue to receive email reminders until you certify (if you don't have one in the system) or recertify (for existing) an annual COI disclosure form.
  3. You will receive an email letting you know your disclosure form was received. If you do not receive this email, confirm you completed the process and were successful in submitting the form.

When is my COI disclosure due?

Your COI disclosure is due annually, between October 16 and December 16.

How often must I disclose?

You must certify/recertify your COI disclosure (1) upon being hired by the University, (2) at least annually thereafter during the fall COI Disclosure Campaign, and (3) within 30 days of acquiring a new potential, perceived, or actual conflict of interests.

How do I prepare for the annual disclosure process?

Keep accurate notes of potential, perceived, or actual COIs you acquired in the previous 12 months.

Make lists of:

  • Your financial interests and those of your spouse or dependent children of >$5000
  • Compensation you receive from intellectual property not funded through the University
  • Outside business relationships related to your University responsibilities
  • Interests (financial or otherwise) that may adversely affect research conducted by students
  • If you have research funded or supported by PHS or NSF, travel that was either paid for, or reimbursed by, an outside entity

How do I certify/recertify my annual disclosure?

Go to the University COI webpage, select Conflict of Interest Disclosure Form.

  • Log-in to the COI portal using your NetID and password.
  • Click on the External Interests box on the left side of the page.
  • Click on Update.
  • Read the information on the Welcome page and then click on the button to either create a new disclosure or edit/submit a previously submitted disclosure. Do not click on the Submit/Edit COA button. That is for requesting approval for Compensated Outside Activities.
  • Respond to each of the five initial screening questions.
  • If you answer "yes" to any of questions 1 - 4, additional details pages will load. Respond to all questions on the details pages.
  • The final page is a Certification page. Read the statements and click the box to indicate your agreement with the statements.
  • The final step is to click the "Submit" button. Your disclosure will not be complete until it is submitted.

How do I navigate between pages?

You can navigate between pages anytime by clicking the page names in the navigation bar. You can use the navigation bar to move forward or backwards and return to pages you have already completed. Clicking the "complete" box automatically directs you to the next page in the form.

How do I preview my disclosure before I submit it?

To preview your disclosure before submitting it, navigate through the pages as described above (i.e., click on each page in the navigation bar). When you have finished reviewing, click on the Back to the Certification Page.

How do I know if my disclosure has been submitted?

After you click the Submit button on the certification page, the page will refresh and the date it was submitted and a PDF print icon will replace the submit button. You will also be sent an email notification confirming your disclosure was successfully submitted.

Why can’t I complete my disclosure and submit it?

If you select the Submit button and get an error message, most likely unanswered questions remain for one or more screening questions or a related detail page.

  • Review the navigation bar at the top of the page. Each page of the disclosure form should have a green check mark next to it.
  • If a page does not have a green check mark, click on that page and complete all unanswered questions on that page.
  • Click on the box at the bottom of the page to indicate that you are done and to lock your answers.
  • Click the Submit button again.
  • If you still receive an error message, contact Michele Dondanville at 775-784-6360 or for assistance.

How do I print my disclosure?

After submitting your disclosure, you have two options for printing it:
Option 1 is available immediately after submitting your disclosure.

  • Do not log out or close the form.
  • From the certification page open the disclosure as a PDF document by clicking on the PDF icon at the bottom of the page.
  • Print the PDF.

Option 2 is available anytime.

  • Go to the University COI webpage, select Conflict of Interest Disclosure Form.
  • Log-in to the COI portal using your NetID and password to display your Disclosure Profile page.
  • On your homepage, select View last disclosure to open your disclosure as a PDF.
  • Print the PDF.

What if I made an error on my disclosure but already submitted it?

To revise a disclosure that has already been submitted, follow the same steps as if you were creating a new disclosure or recertifying.  Your responses on the previously submitted disclosure will flood into the form and you can change them as necessary.

How do I log out of InfoEd?

From any page within the form, select the Save button (top left of each page) and close the browser window.

From your Discloser Profile page, select the Exit button (top left the form).

What if I am uncertain as to whether or not I should disclose a particular outside activity or financial relationship?

If, after reading the questions on the COI Disclosure form, you are unsure as to whether or not you should report an financial, business, or student research interest, you should err on the side of caution and disclose the information. If an issue should arise in the future, having reported the interest/activity offers some protection to you and the University in terms of how the matter is perceived by others. Failure to report an interest/activity may be misinterpreted as a desire to hide the interest/activity. No one is criticized for "over-reporting."

I am a Faculty member and have no external financial, business, or student research interests; third-party paid travel; or outside compensated activities. Do I still have to submit a COI Disclosure?

Yes. All University employees must submit an annual COI Disclosure form. All full-time University and UNR Med faculty  must report compensated outside activities. Simply answer "No" to each of the screening questions in the form and submit.

I am a classified employee and have no external financial, business, student research interests; or travel paid by a third party. Do I still have to submit a COI Disclosure?

Yes. All University employees must submit an annual COI Disclosure form. Simply answer "No" to each of the screening questions in the form and submit.

I am certain I have no conflicts. Do I still have to submit a Disclosure Form?

Yes. All University employees must submit an annual COI Disclosure form. Simply answer "No" to each of the screening questions in the form and submit.

When will my disclosure be reviewed?

Disclosures of a routine and de minimis nature may qualify for immediate review by the COI Designated Official. More complex disclosures are presented for review and consideration by the COI Committee.

What is a conflict of commitment?

A conflict of commitment may occurs when University/UNR Med faculty receive compensation from outside entities to participate in outside scholarly activities or to provide service and the activity/service affects her/his performance of duties as contracted or as otherwise specified by the University/UNR Med.

Your direct supervisor is in the best position to determine whether your outside activities pose a conflict of commitment and is your initial contact for discussing your options for eliminating conflicts of commitment. In order to assure the elimination of the conflict of commitment, your direct supervisor may refer a compensated outside activity for review by the COI Designated Official and consideration of a Management Plan.

See the University Administrative Manual for guidance for faculty involvement in compensated outside activities.

What is disclosable travel?

Disclosable travel is travel paid or reimbursed to you by a third party and only applies to employees involved in the design, conduct, or reporting of research conducted or supported by the Public Health Service (PHS), National Science Foundation (NSF), or other agencies/sponsors that adopted the PHS regulations.

PHS/NSF regulations exclude travel paid by:

  • the University directly or through a sponsored award to the University;
  • U.S. Federal, state or local government agencies;
  • U.S. Institutions of higher education or U.S. research institutes; and
  • U.S. academic teaching hospitals or U.S. medical centers that are affiliated with U.S. Institutions of higher education.

What can I do to facilitate my award set-up?

To facilitate your award set-up, ensure that COI disclosures have been certified/recertified for all investigators and key personnel (i.e., persons identified by the PI as being responsible for the design, conduct or reporting of the research) for the project. COI disclosures should be submitted with enough time to allow the COI Committee to evaluate the interest and develop a COI Management Plan (if warranted) prior to the date you expect the award to be set-up. NOTE: Some federal agencies require COI disclosure certification/recertification prior to submission of the grant proposal.

What is a Management Plan?

A Management Plan is a written agreement between the University and an employee with a disclosed potential, perceived, or actual conflict of interest. The purpose of the Management Plan is to manage, reduce, or eliminate the conflict of interests.

Will the content of my disclosure form be kept confidential?

Your disclosure will be maintained in confidence as far as possible. The information you submit will not be shared except with those who have a need to know, although requirements for public disclosure apply to conflict of interests related to research funded or supported by the PHS.

Specifically, PHS regulations require that prior to the expenditure of any funds under a PHS-funded research project, the University must make publicly available information about any significant financial interest (SFI) that has been determined to be a financial conflict of interest (FCOI) and is held by senior/key personnel.

The information that University is required to provide includes:

  • •the Investigator's name;
  • •the Investigator's title and role with respect to the research project;
  • •the name of the entity in which the significant financial interest is held;
  • •the nature of the significant financial interest; and
  • •the approximate dollar value of the significant financial interest (in dollar ranges, e.g., $5,000-$9,999; $10,000-$19,999)

How will the information from my COI disclosure form be used?

Your responses to questions on the COI disclosure form will be reviewed by the COI Designated Official and may be referred to the COI Committee for development of a COI management plan.

Why won’t the Office of Sponsored Projects set up my award while my disclosure status is pending?

Most federal regulations require that prior to the expenditure of any funds under an award, any conflicts of interest are satisfactorily managed, reduced or eliminated in accordance with the Institution's COI policy. This cannot be confirmed for pending COI disclosures.