Conflicts Survey

All WCM Workforce Members are required to complete a Conflicts Survey.

The Conflicts Survey is required at a minimum once annually; however, should any financial interests or external committments change over the course of the year, an update to the Conflicts Survey is required within thirty (30) days of the change.

For those who have no external activities or financial interests to disclose, submission of a Conflicts Survey is still required as a certification of such.

If you have external activities or financial interests to disclose you will be required to answer the primary questions plus an additional set of questions for each entity with which you have a financial interest or relationship. For example, if you have financial interests in three different entities, you will be required to answer the additional set of questions for each of those entities.

FDA Research

If you are an Investigator on research that is overseen by the Food & Drug Administration (FDA):

You will also need to report financial conflicts to the research sponsor for their reporting, as required, to the FDA. Further information on conflict reporting can be found on the FDA-Sponsored Research website.

Please refer to the Policies and Forms page for specific definitions on what constitutes a financial conflict of interest and/or commitment that may be a conflict to the institution.

External Consulting Agreements

For information about External Consulting Agreements:

External Consulting Agreements are considered to be personal arrangements between WCM Workforce Members and the Company. Therefore, WCM does not provide legal review or negotiation assistance for such agreements or, otherwise, represent Workforce Members in this individual capacity. However, for WCM’s protection, University Counsel requires that a non-negotiable Addendum be signed by both parties - the Company and Workforce Member - and incorporated into the Consulting Agreement. The Workforce Member will also need approval from their Department Chair, Division Chief, or supervisor in order to pursue the outside consulting, and must update their Conflicts Survey accordingly.

To download the Non-Negotiable Contract Addendum for consulting and service agreements, click here.

To review the Contract Addendum FAQs, click here.

Travel

Travel disclosures should be reported on your Conflicts Survey in Weill Research Gateway.

Travel for a U.S. Non-Profit Entity

You must report travel sponsored or reimbursed by a single U.S. non-profit entity if:

The trip cost was more than $5,000;
Multiple trips for that entity in aggregate exceed $5,000 in a 12-month period;
You receive more than $5,000 for services from that entity in a 12-month period; or
A combination of trips and services in aggregate from a single entity exceeds $5,000 in a 12-month period.

You do not have to report travel reimbursed or paid for by:

Cornell University;
a federal, state, or local government agency;
a U.S. non-profit institution of higher education as defined at 20 U.S.C. 1001(a);
a U.S. academic teaching hospital, U.S. medical center; or
a research institute that is affiliated with an institution of higher education.

There are additional rules for individuals applying for or funded by Public Health Services (PHS), which includes the National Institutes of Health (NIH) and other non-profit agencies that chose to invoke PHS COI policy.

Sponsored travel means (a) travel expenses paid to an Investigator or travel paid on an Investigator's behalf by a single entity in any 12-month period and/or (b) travel reimbursed to or paid on behalf of an Investigator's spouse and dependent children by a single entity in any 12-month period.

Travel for a For-Profit Entity

All travel paid or reimbursed by for-profit entities must be disclosed within thirty (30) days of completing travel.

To complete a Conflicts Survey:

Log into WRG (https://wrg.weill.cornell.edu) with your CWID and password.
Navigate to the left-hand side of your screen to the Conflict of Interest tab.
Select the Access Conflicts Survey button.
From the next screen, you may: a) view your last Conflicts Survey; and/or b) create/edit your current Conflicts Survey.
Complete the form by answering all relevant questions. Be sure the Primary Questions and any supplemental financial interest questions related to disclosed entities have been answered accordingly.
Click the checkbox at the bottom of the page to the left of "I certify…" to attest to your disclosures.
After the page refreshes, click the Submit button at the very bottom of the page.
Once successfully submitted, you should receive a confirmation email. If you do not receive confirmation or you encounter technical issues (i.e., trouble logging in, problems within the survey, or error messages) please contact wrg-support@med.cornell.edu.