Q. Why does EVMS require that I disclose my interests?
A. EVMS collects annual disclosures in order to ensure that outside financial or personal interests/relationship do not create a conflict of interest or conflict of commitment with regard to an individual’s teaching, research, and/or clinical duties. For more information, please see the Policy on Disclosure of Interests.
Q. Who must complete a disclosure and how often is it required?
A. All EVMS employed faculty, and faculty in EVMS affiliate departments (Pediatrics, Radiology, Neurology, Urology and Emergency Medicine), must complete a disclosure at least annually. EVMS Community Faculty generally do not need to complete the disclosure unless they are key personnel on a research study, in which case that person will be notified individually. Please note that you are also required to update your disclosure within 30 days of becoming aware of, acquiring, or entering into an arrangement for an external financial interest or time commitment.
Q. How do I complete disclosure?
A. All disclosures should be completed through the InfoEd COI module. You will log in by using your EVMS username and password (Novell Login). Once logged in select the “External Interests” tab on the left and “Update” under that tab (even if this is your first disclosure), then follow the instructions from there. The InfoEd User Guide for Annual Disclosure of Interests, available on myPortal, has several tabs to help you complete the module appropriately.
Q. Is an annual disclosure the same thing as a conflict of interest?
A. No. The annual disclosure collects information about the sorts of interests, relationships, and activities that could create a conflict of interest, but is not, in itself, a conflict of interest. In order to determine if a conflict of interest exists, the information disclosed must be reviewed and compared to the activities that the individual performs at EVMS. For example, a conflict of interest could exist if a financial interest in a pharmaceutical company leads to personal gain for an individual or his/her family member, influences, or appears to influence, that individuals ability to exercise objectivity in a research study that is funded by that company.
Q. What is a “conflict of commitment”?
A. A conflict of commitment is another type of conflict of interest. A conflict of commitment exists when non-EVMS activities and undertakings are so substantial or demanding that they deprive EVMS of appropriate time and effort or they impair an individual’s ability to perform his/her responsibilities to EVMS.
Q. I submitted my annual disclosure, now what?
A. Once submitted, your disclosure will be routed to your Chair for review and to determine if a conflict of commitment exists, if it does, your Chair will determine the best way to manage same. If you also conduct research and/or are involved in patient care activities your disclosure will be sent to the EVMS Office of Research and/or EVMS Medical Group administration, as applicable, for review and management as necessary.
Q. Will others have access to the information I report on this form?
A. In addition to those listed above, other administrative offices or groups at EVMS (e.g. Office of the General Counsel, Conflict of Interest Committee, and/or the EVMS Board of Visitors Audit and Compliance Committee) may review your annual disclosure if they have a need to know. EVMS may also be required, as part of its reporting or disclosure requirements, to provide this information to government entities or as otherwise required by law, regulation or contract.
Q. What if/when do I need to make changes to my disclosure?
A. Once submitted (even if by error), all changes will be considered an update and you should consult the “Updating/Recertifying” tab. Please note that per the Policy on Disclosure of Interests you must update your disclosure within 30 days of becoming aware of, acquiring, or entering into an arrangement for an external financial interest or time commitment.
Q. Who may I contact for more information about conflict of interests and commitments or for help completing my annual disclosure?
A. For questions related to annual disclosures, please contact ogc@evms.edu,
For questions related to research conflicts of interest or management of same, please contact coi@evms.edu or
757. 446.8404/7247.