Welcome to the Weill Cornell Medicine (WCM) Conflicts Management Office (CMO). 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 of Interests and Commitments
Every Weill Cornell Medicine faculty member and all staff is required to complete the Conflicts Financial Interests and Commitment survey. For those who have no interests to disclose, the submission of the Conflicts Survey is required as a certification of such. The Conflicts Survey is required at a minimum once annually; however, should any financial interests change over the course of that year, an update to the Conflicts Survey is required within 30 days of the change. Please refer to the policies linked below for specific definitions on what constitutes a financial interest and/or commitment that may be a conflict to the institution.
Those receiving NIH funding will also need to complete the tutorial below. If you are a researcher that falls under the PHS FCOI regulation, you must complete the NIH Tutorial on Financial Conflict of Interest.
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.
Conflicts of Interest Training
Research personnel on any grants or contracts funded by an agency or organization that follows the Public Health Service 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: https://nexus.weill.cornell.edu/display/WRGOUTREACH/CITI+Training+Update for instructions, additional information, and FAQs.
The Conflicts Survey
The WCM Conflicts of Interest and Commitment Policy requires all WCM faculty members and staff involved in research to report information about potential conflicts of interest.
The Conflicts Survey can be accessed through the WCM Weill Research Gateway. The survey asks three initial questions. One determines whether or not you are involved in any research at WCM, the second determines whether or not you have family member(s) employed at WCM, and the third determines whether or not you have any financial interests which need to be disclosed. If you do not have any financial interests to disclose, then you will not need to answer any additional questions. If you have financial interests to disclose you will be required to answer the first three 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.
If your external financial interests change, you must update your survey within thirty (30) days of your new relationship. The amendment process is completed by accessing the Weill Research Gateway (WRG) and updating the Conflicts Survey.
Travel disclosures can be made through your conflicts survey in Weill Research Gateway.
All paid or reimbursed travel paid or reimbursed by "for-profit" entities must be disclosed within 30 days of completing travel.
Reimbursed travel expenses and other compensation greater than $5,000 per year in aggregate from a single non-profit entity need to be reported. This means that you only have to report travel sponsored or reimbursed by a single 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.
To the extent possible, listing all potential travel prospectively on this disclosure will reduce or eliminate the need to file updates throughout the year.
If you need further explanation about the Conflicts Survey, please contact the Conflicts Management Office at (646) 962-8200 or firstname.lastname@example.org.
If you are involved in research at WCM, your Conflicts Survey must be submitted prior to completing the Study Specific Report.
Completing a Study Specific Report (SSR)
A study specific report must be made with each new grant proposal and/or research protocol (both human and animal subjects) application. The purpose of the study specific disclosure is to determine - for each study - whether there is a financial interest that needs to be managed In addition, a new SSR must be completed at the time of protocol Continuing Review and/or grant renewal, and at any time thereafter- if a change in circumstances has occurred- since the project has begun. Please see below for guidance on disclosing interests within an Informed Consent Form (ICF).
To complete a SSR, visit the Weill Research Gateway (WRG) and sign in with your WCM user name and password. If you have not yet created a Conflicts Survey you must do so first. Once your Conflicts Survey has been completed click on the button labeled "Edit/Submit Study Specific Report (SSR)." Please note: If you do not have a study specific conflict to report, you do not need to submit a SSR.
All investigators* and/or Key Personnel that are not WCM employees but are named on WCM proposals or protocols are considered External Investigators. External investigators must complete an External Non-WCM Study Specific Report. External Investigators can obtain an External Non-WCM Study Specific Report form by contacting the Conflicts Management Office at (646) 962-8200 or email@example.com.
* The term “investigator” refers to individuals identified by the Principal Investigator who regardless of title or position, have the ability to make independent decisions related to the design, conduct or reporting of the research. This includes but is not limited to post docs, co-principal investigators, research scientists, research associates, consultants, collaborators, and graduate students regardless of whether they are listed as key or non-key personnel, paid or non-paid
External Non-WCM Use Only
Unlike WCM personnel, all external users must complete an external SSR regardless of whether or not they have any relationships to disclose.
Public Requests for Information
Weill Cornell Medicine (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:
- 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:
Conflicts Management 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.
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
- 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.
- 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).
- Ensure that your WCM Annual Survey Statement of External Financial Interests and External Time Commitments are complete, accurate and up-to-date.
The 2018 data review, dispute and corrections period runs from April 1–May 15, 2019.