Transition to Annual Disclosure Model
Effective: April 13, 2026
UNC’s Conflict of Interest (COI) Program is moving to an annual disclosure model to simplify reporting and reduce administrative burden, while maintaining the 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 submit 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 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
Upcoming Office Hours (link to join call):
- Monday, April 6, 4-5pm
- Tuesday, April 7, 1-2pm
- Wed, April 8, 10-11am
- Thursday, April 9, 3-4pm
- Friday, April 10, 12-1pm
Frequently Asked Questions:
Disclosures, Training & Management Plans
1. Who needs to complete annual disclosures?
All individuals involved in the design, reporting, and conduct of research must complete the COI annual disclosure. This includes both sponsored projects and human subjects research. See #2 in “Research Administration” for a list of roles that require COI disclosure on RAMSeS IPF and on IRBIS applications.
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 Resources
1. How have University FCOI Policies changed?
We retired the University’s Conflict of Commitment and Individual Conflict of Interest Policy, and replaced it with three stand-alone policy documents, for brevity and accessibility.
- Policy on Individual Financial Conflict of Interest in Research
Addresses disclosure, review, and management of financial conflicts of interest in research, aligns with U.S. Public Health Service (PHS) regulations, and supports the COI Annual Disclosure process. - Conflicts of Interest for University Employees Policy
Establishes baseline expectations for identifying and managing conflicts of interest across all University activities, including administrative, operational, and procurement functions. - Conflict of Commitment Policy
Defines expectations for balancing University duties with external professional activities and outlines how conflicts related to time and effort are reviewed and managed.
Please review this publication for more information on our policy changes.
2. When will we transition into the annual disclosure model?
Campus-wide, the annual disclosure form released on Monday, April 13, 2026. The system “soft-launched” on Friday, April 10, 2026, for individuals with action items on that day and for coordination with COI partners across campus. Please complete your annual disclosure as soon as possible to assist with transitioning to this new model.
Update, 4/13: We are staggering access to AIR throughout today to avoid overloading the Research servers. If you receive an error message, please check back later in the day.
3. When should I complete your disclosure?
Complete your disclosure as soon as possible, as project and protocol actions will check against your annual disclosure.
4. Upon submitting a disclosure, how long does it take to link to projects/protocols?
AIR transmits data to RAMSeS and IRBIS every five minutes. Please contact COI if you have any questions regarding a submitted disclosure.
5. How do I get support?
The Conflict of Interest office is available via email or phone. Additionally, Office hours will be held over Zoom (link to join call) at:
- Monday, April 6, 4-5pm
- Tuesday, April 7, 1-2pm
- Wed, April 8, 10-11am
- Thursday, April 9, 3-4pm
- Friday, April 10, 12-1pm
Research Administration
1. For whom is COI annual disclosure required?
All individuals involved in the design, reporting, and conduct of research must complete the COI annual disclosure.
2. What roles on RAMSeS IPFs and IRBIS applications must complete COI?
Submit a disclosure if you are responsible for the design, conduct, or reporting of research or other sponsored projects covered by the Individual Financial Conflict of Interest in Research Policy.
Certain roles in RAMSeS and IRBIS are defined to fall within the above criteria.
Roles in RAMSeS:
- Lead PI
- PI
- Investigator
- Postdoctoral Research Associate
- Clinical Research Coordinator
- Fellow
- Fellow (individual NIH Fellowship)
- Other Key Participant (faculty only)
- Faculty Advisor (only when Lead PI is a Post Doc)
- New Lead PI (award only)
Roles in IRBIS:
- Principal Investigator (including external_
- Faculty Advisor
- Co-Investigator
- Project Manager
- Study Coordinator
Contact the COI office if you have any questions about whether you should complete a disclosure. AIR transmits data to RAMSeS and IRBIS every five minutes.
3. When should COI disclosure be completed?
As per the Individual Financial Conflict of Interest in Research Procedure:
- Complete and certify a COI disclosure in AIR before engaging in research activities covered by the FCOI Policy.
- Update and certify the COI disclosure at least annually during the annual disclosure period, even if you have no interests to report.
- Update the COI disclosure before submitting new, renewal, or revised PHS applications.
- Update disclosures within 30 calendar days of acquiring or discovering a new interest or a change in an existing interest.
- Update disclosures when requested by the University or the COI Office.
- Respond promptly to requests from the COI Office for clarification or additional information.
4. How do I add or remove personnel on the Conflict of Interest Review Grid in RAMSeS or IBIS?
- If you are actively working on a proposal submission, contact the OSP or SPO Proposal Specialist listed on the RAMSeS IPF.
- If your request is post proposal submission and related to an active award/project request being supported by your department’s SPS, please contact them to process the removal.
- For all other requests, contact [email protected].
- If you are actively working on an Institutional Review Board application, contact the analyst listed on the application.
Important: Individuals with the Lead PI role cannot be inactivated in RAMSeS. If the original Lead PI is receiving disclosure reminders, email [email protected]. No changes are needed in RAMSeS.
5. How do external users complete their COI disclosure?
External users will receive an email notification when listed on a protocol or project. with a special link to guide them to the annual disclosure. During the transition to an annual disclosure model, they do not need to take action before receiving this protocol or project specific notification.
Their email address will allow them to enter back into the same annual disclosure when they need to make updates or renew their disclosure on an annual basis.
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
Conflict of Interest Director, Officer
Raha Khademi
Conflict of Interest Director, Conflict of Interest Officer
Conflict of Interest
[email protected] | 919-843-9953