Conflicts of Interest

Welcome to the Weill Cornell Medicine (WCM) Conflict of Interest ("COI") Office. On this page, you will find information to assist you in understanding the meaning of the terms "Conflict of Interest" and "Conflict of Commitment." We also provide information concerning University and federal policies regarding conflicts of interest.

WCM Conflicts Survey

All WCM faculty members and staff are required to complete the Conflicts Survey. The Conflicts Survey is required at a minimum once annually; however, should any financial interests change over the course of the year, an update to the Conflicts Survey is required within 30 days of the change.

For those who have no interests to disclose, the submission of the Conflicts Survey is required as a certification of such. If you have financial interests to disclose you will be required to answer the initial questions plus an additional set of questions for each entity with which you have a financial interest. 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 conflicts reporting in FDA-Sponsored Research.

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

External Consulting Agreements

External Consulting Agreements are considered to be personal arrangements between the WCM faculty member and the Company.  Therefore, WCM does not provide legal review or negotiation assistance for such agreements or, otherwise, represent faculty members in this individual capacity.  However, for WCM’s protection, University Counsel requires that a non-negotiable Addendum be signed by the Company and incorporated into all employee Consulting Agreements.  The faculty member will also need his/her department chairperson’s approval in order to pursue the outside consulting, and must update their Conflicts Survey accordingly. 

To download the Model Addendum for Consulting Agreements, click here.

Travel

Travel disclosures can be made through your conflicts survey in Weill Research Gateway.

Travel for a U.S. Non-Profit Entity

Reimbursed travel expenses and other compensation greater than $5,000 per year in aggregate from a single U.S. non-profit entity need to be reported.

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

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

You do not have to report travel reimbursed or paid for by Cornell University, nor travel paid by:

• 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 paid or reimbursed travel paid or reimbursed by "for-profit" entities must be disclosed within 30 days of completing travel.

If you need further explanation about the Conflicts Survey, please contact the Conflict of Interest Office at (646) 962-8200 or conflicts@med.cornell.edu.

Conflicts of Interest Training

Research personnel on any grants or contracts funded by an agency or organization that follows the Public Health Service (PHS) FCOI regulations (NIH, AHRQ, ACS, AHA, CDC, etc.) are required to complete conflicts training. This training must be renewed every four years.

Training is available via the Weill Research Gateway (WRG) by using your WCM CWID and password.

Please visit: CITI Training Instructions for instructions, additional information, and FAQs.

External Investigators and Research Personnel

All external (non-WCM) investigators and research personnel must complete an External Study Specific Report (SSR) regardless of whether or not they have any relationships to disclose.

To download the WCM External SSR, click here.

Public Requests for Information

WCM is committed to overseeing the conduct of research in a manner that ensures the integrity of the research process and maintains the public trust and that of sponsors in the integrity and credibility of its faculty, its staff, and its research programs. Cornell's policy 1.7, Financial Conflict of Interest describes WCM's commitment and procedures related to the identification and management of real or apparent conflicts of interest that arise from the intersection of personal financial interests and research activities. 

To comply with the Public Health Service (PHS) regulations on Responsibility of Applicants for Promoting Objectivity in Research for which PHS Funding is Sought [(42 C.F.R. Part 50, Subpart F) and Responsible Prospective Contractors (45 C.F.R. Part 94)], Weill Cornell Medicine will make available within 5 business days upon receipt of a request as described below, of information concerning Significant Financial Interest (SFI) disclosed to WCM that meets the following criteria:

 NIH (National Institutes of Health) Conflicts of Interest (COI) Training Requirements FAQs

• The individual for whom information is sought, is identified by WCM in the grant application, progress report, or any other required report submitted to the NIH as a senior/key personnel on an NIH grant or cooperative agreement for which a notice of award was issued on or after August 24, 2012;
• The SFI is still held by the senior/key personnel for the NIH-funded research project;
• WCM has determined that the SFI is related to the NIH-funded research; and
• WCM has determined that the SFI is a Financial Conflict of Interest.

If your request meets the conditions outlined above, please follow these instructions:

• Complete this  form for each SFI for which you are seeking information. Incomplete forms will not be considered and will not be responded to.
• Please print the completed form, sign and send it by regular mail to:
  Conflict of Interest Office – Office of Research Integrity
  Weill Cornell Medicine
  575 Lexington Avenue, 9th Floor
  New York, NY 10022
• WCM will respond via email to the email address provided in the form. If a paper copy is required, please enclose a self- addressed, postage paid envelope. Mailed responses will be postmarked no later than five (5) days after receiving a valid request (as described above) at the email address or the mailing address provided above.

Start-up Company Involvement

WCM, working in close proximity with the Center for Technology Licensing (CTL),supports the efforts of its faculty and other research personnel to participate in the creation, development and licensing of WCM intellectual property (IP) through the formation of start-up companies. However, there exists the potential for a conflict of interest in the formation of such company. The best time to address any potential conflict of interest is in the planning/preliminary phase of the start-up company. Accordingly, the COI Office is available to provide advice and guidance through the process.

As part of the start-up company conflict review, please complete the Start-up Intake Form and reach out to the COI Office during the earliest stages of the start-up to best manage any potential conflicts. For additional information, please refer to the WCM Start-up Guidelines found in the Policies and Forms section below.

Open Payments

The Open Payments Program facilitates greater transparency with regard to financial relationships between manufacturers, physicians and teaching hospitals. This legislation requires that manufacturers of drugs, devices, biologicals and medical supplies report to the Centers for Medicare & Medicaid Services (CMS) any payments or other transfers of value made to physicians and teaching hospitals. "Physicians" include those who are legally authorized to practice medicine, osteopathy, dentistry, dental surgery, podiatry, optometry and chiropractic medicine (note that medical residents are specifically excluded from this definition). Additional information for physicians about the Open Payment Program is available from the Centers for Medicare & Medicaid Services.

Important Information for WCM Physicians

• "Payments" are defined very liberally. E.g., meals or other items of value greater than $10 will be reported.
• Reporting of payments is done by industry, not by WCM.
• WCM staff members do not have access to reported information and therefore cannot review this information for you.
• Open Payments information will be published on a public website and will likely be of interest to the press and others. 
• WCM policy requires all faculty members to review Open Payments industry postings to ensure that the information is accurate and, when necessary, work with posting entities to correct inaccuracies.

WCM Physician Requirements

1. If you have not already registered with the CMS, register through the CMS Enterprise Portal. Note that you may already have an Enterprise IDentity Management (EIDM) account if you use the Health Insurance Oversight System (HIOS), the Medicaid And CHIP Program (MACPro) System or other CMS systems.
2. If you have not already registered for Open Payments, register through the CMS Open Payments System to review what has been reported about you and dispute it (if necessary).
3. Ensure that your WCM Annual Survey Statement of External Financial Interests and External Time Commitments are complete, accurate and up-to-date.

WCM-Qatar

WCM-Q is part of Cornell University and functions as an entity of the WCM-NY Conflict of Interest Office.

Study-Specific Conflict of Interest

All research team members, external and internal, who will be conducting human subject research in collaboration with WCM-Q must complete the manual WCM-Q COI Study Specific Form (provided in the link below) regardless of whether or not they have any relationships to disclose.

For Animal Research, all External animal researchers (other than WCM-NY, the Hospital for Special Surgery (HSS), and the Memorial Sloan Kettering Cancer Center (MSK)) who are listed on grants as sub awardees must complete the WCM-Q COI Study Specific Form (provided in the link below) regardless of whether or not they have any relationships to disclose.

To download the WCM-Q COI Study Specific Form, click here.