Completing an Assigned Annual Conflict of Interest (ACOI)
Written by Michelle Henley
Updated at July 26th, 2024
Accessing the ACOI Disclosure
Pre-assigned campaign participants will be sent an email containing a link. The link will route the user directly to their campaign disclosure.
Note: Users who are not pre-assigned will be assigned a link by their organization outside of the email process defined below.
When a user clicks the link for the first time, a new request ID will be generated. IDs are in New status until the user begins the questionnaire and either Submits it or saves it as a Draft.
Pre-assigned campaign disclosures can also be found in the user's Action Items table under the Campaigns tab.
If the user is provided a link, rather than pre-assigned, the campaign disclosure will be in the user's Action Items table after clicking the link for the first time.
Once a user submits their campaign disclosure, the campaign is moved out of the Action Items table and into the user's Submissions Table under Approvals and Disclosures.
Submitting a Campaign Disclosure
After a user clicks the link in the email, the campaign disclosure can be completed by completing the questionnaire and submitting the information. Depending on your organization's specifications, the disclosure might simply be recorded or go to an approver(s) for review.
If the user already has an existing COI when they are assigned to complete the ACOI disclosure, the system will automatically link the previous COIs to the ACOI.
Click below to expand more information.
COI (Conflict of Interest) within a Campaign (ACOI)
COI (Conflict of Interest) within a Campaign
- The system will automatically link a user's previous Conflict of Interest (COI) disclosures to their campaign disclosure; AND/OR
- Based on a submitter's answers to the Annual Conflict of Interest (ACOI) questionnaire, the user may need to disclose a new COI.
Previous COI disclosures that are linked may require review before the user can submit their ACOI request.
New COI Disclosures
If a new COI is required based on the submitters' answers, the system will display a message indicating that the user must also complete one.
Click, Add Disclosure to complete and submit the COI disclosure.
Previously Existing COI Disclosures
If the user already has an existing COI when they are assigned to complete the ACOI disclosure, the system will automatically link the previous COIs to the ACOI.
Note: Rejected, Retired, or Draft COIs where the user has not yet chosen a category will not be linked.
Based on the category selected in the COI, it will be displayed next to the relevant question in the ACOI.
For example, in the screenshot below, the previous COI that disclosed outside work is displayed under the question pertaining to outside work.
Review & Take Action
Depending on the current status of the associated COIs, the assigned submitter may need to review all previous COIs and take action.
COIs that require review are flagged with a red triangle, while COIs that do not require action are indicated with a green circle.
Note: Once a COI is resubmitted, it is required to go through the entire approval process defined by your organization.
COIs Still in Draft
If the previous COI is in Draft status and the user has already selected a COI category, the user will need to submit the COI for approval before submitting the ACOI.
Note: If the COI category has not been selected, the COI will not be displayed within the ACOI.
COIs Already In Progress
If the COI is already In Progress, the user can view it by clicking Review; however, no action is needed.
Cleared/No Conflict COIs
If the COI is already Cleared or Approved as No Conflict, the user must resubmit the review for approval.
Note: Once a COI is resubmitted, it is required to go through the entire approval process defined by your organization.
First, click Review.
Once the user has reviewed the COI, click Confirm Request in the top right corner to resubmit the COI.
Retiring a COI
Note: When retiring a COI, it will be removed from the ACOI.
How to Retire a Conflict of Interest Disclosure
A Conflict of Interest (COI) disclosure can be marked from either Cleared or No Conflict to Retired by the submitter once the circumstances of the conflict are no longer applicable.
By retiring a conflict, a user is acknowledging that the previously disclosed conflict no longer exists or that the user's involvement in an activity that gave rise to a potential conflict has ended.
Note: Retired conflicts cannot be reopened.
To change a Conflict of Interest Disclosure to Retired, first open the request. Next, click Retire Conflict.
A Retire Conflict pop-up box will open. The user is required to enter the date the conflict ended and a comment regarding why the conflict is no longer applicable. Once complete, click Confirm.
By clicking Confirm in the Retire Conflict screen, the system will:
- Send out a notification email to the Approver(s) who Cleared your Conflict to notify them that the conflict has been retired.
- Change the request status to Retired.
FAQ
Can a retired conflict be reopened? No. Retired conflicts cannot be reopened; however, the user can create a new COI disclosure.
Can approval be required before allowing the user to retire a disclosure? No. Retiring a conflict does not follow an approval workflow.
How to Update a COI
How to Update a Conflict of Interest Disclosure
Conflict of Interest disclosures with a status of In progress, No Conflict, or Cleared can be updated by the submitter by following the instructions below.
Rejected Conflict of Interest disclosures cannot be updated, but they can be retired by following the instructions found in this article: How to Retire a Conflict of Interest Disclosure.
Canceled or Deleted Conflict of Interest disclosures cannot be updated.
To update a Conflict of Interest Disclosure, first open the request. Next, click Update Disclosure.
An Update Disclosure pop-up window will come up. The submitter will be required to enter comments and click Confirm.
By clicking Confirm in the Update Disclosure pop-up window, the system will:
- Change the activity status to Update Pending.
- Send an email to the current approver notifying them that the request is being updated by the submitter.
After making all needed changes, click Submit Disclosure.
Clicking Submit Disclosure will open the Approvers pop-up window. Click, Confirm to submit your changes for approval.
By clicking Confirm in the Approvers pop-up window, the system will:
- Change the disclosure status to Awaiting Approval.
- Send an email to the current approver notifying them that the request has been updated and is ready for their approval.
Updating a Campaign (ACOI) Disclosure
Once an ACOI disclosure has been submitted, it cannot be updated, changed, or canceled in any way. ACOI
Note: Ad hoc COI disclosures can still be updated or retired.