Transition to Annual Disclosure Model
Effective: Early 2026
UNC’s Conflict of Interest (COI) Program is moving to an annual disclosure model to simplify reporting and reduce administrative burden, while maintaining highest standards of accountability and compliance. Investigators will submit an annual disclosure once per year and update as needed. This shift reflects a researcher-first approach to align with national best practices and the core principles of the UNC Research Roadmap.
From the Vice Chancellor’s desk:
“Our research enterprise is evolving to be more agile, efficient, and impactful. Guided by the UNC Research Roadmap, this transformation enhances compliance, reduces administrative burden, and creates a clearer path to collaboration and commercialization.
A strong, transparent COI program is essential for protecting research integrity, supporting discovery, and ensuring that our work delivers meaningful benefits for North Carolina and the world.”
— Penny Gordon-Larsen, Vice Chancellor for Research
Read the full article in Carolina Discoveries:
Why the change?
Researcher-first model:
- Annual model: Under an annual submission model, each investigator will their annual disclosure once per year and update as needed.
- Reduction in volume: Research Compliance Services has been working over the last year to create a new COI model that drastically reduces administrative burden. We anticipate a reduction in:
- Over 60,000 disclosures per year to 8,000 disclosures
- 1,576 management plans (FY2024) to under 300 estimated management plans
Focus on value:
- Peer review: This is approach is informed by external review with peer institutions.
- Quality over quantity: Administrative and disclosure simplification should facilitate greater accuracy, management, and compliance.
Resources:
We are committed to supporting and informing our colleagues in the Research community during the transition to annual disclosure model. Resources will include:
- A revised Conflict of Interest website
- Annual disclosure Office Hours
- Training and resources
- Communications through all major Research communication lists and fora
Frequently Asked Questions:
Disclosures, Training & Management Plans
1. Who needs to complete annual disclosures?
All investigators involved in sponsored projects or human subjects research must complete an annual disclosure before participating in research.
2. When do I need to complete my annual disclosure?
Investigators must certify disclosure:
- Annually
- Within 30 days of acquiring a new financial interest, or a change in a previously reported one
- When prompted by the University.
Delays in disclosure will postpone sponsored project setup and human subjects review.
3. How do I complete COI training?
COI training is now fully integrated into the disclosure. By initiating your annual disclosure, you will automatically complete PHS-compliant training.
Additionally, COI training has been redesigned with a focus on what you need to disclose.
4. What do I disclose?
Disclose:
- Income from consulting, honoraria, paid authorship, or other professional services
- Equity interests in publicly or privately held companies
- Intellectual property rights and any related income
- Sponsored or reimbursed travel from non-University sources, including all international travel
- Service in external executive, advisory, or board roles (whether compensated or not)
- Gifts that directly support the investigator’s research
Do not disclose:
- Salary, stipends, or compensation paid by UNC
- Income from U.S. government agencies or U.S. academic institutions
- Investments in diversified mutual funds you do not control
- Travel paid for by UNC or through an OSP-facilitated project
If you’re unsure whether to disclose something, contact the COI Office for guidance.
5. How are management plans changing?
Management plans will now focus on addressing Financial Conflicts of Interest (FCOIs) as defined by Public Health Service (PHS) regulations. The total number of management plans is expected to decrease as oversight becomes more targeted.
Transition & Timeline
1. When will we transition into the annual disclosure model?
| TBD | Annual Disclosure opens. |
| TBD – Early 2026 | Investigators populate their annual disclosure. |
| Early 2026 | All sponsored programs and all IRBs move to the new model. |
2. How will this transition impact current sponsored projects and protocols in January?
IPFs and IRBs will be processed under the old rule-set (e.g. “project-specific disclosures”) until February 9, 2026. This will allow the community to populate annual disclosures before the transition.
On February 9, 2026, incoming awards and protocols will be checked against the investigator’s annual disclosure.
About us
1. Who is managing this transition?
Quinton Johnson, Associate Vice Chancellor for Research Compliance and COI Officer, is leading the transition with Research Compliance Services and the Conflict of Interest Office. Their shared goal is to make compliance more intuitive and seamless for the research community.
2. How can I stay up-to-date on this transition?
Updates will be shared through office hours, mailing lists, and unit-level presentations by request. You can also reach out to Research Compliance Services with questions.
Check back at this webpage for additional resources.
Contact:
Conflict of Interest Office:
[email protected] | 919-843-9953
COI Officer:
Quinton Johnson
Assistant Vice Chancellor for Research Compliance
Research Compliance Services
[email protected] | 804-514-3175
Deputy Director, COI:
Raha Khademi
Deputy Director
Conflict of Interest
[email protected] | 919-843-9953