Office of Legal Affairs and General Counsel

Conflict of Interest Training

All Individuals at the Institution are encouraged to take the Institution’s training* every 4 years.

The Institution’s training* every 4 years is required by the following Individuals:

  • Principal Investigators (This includes Scientists,
  • Senior Technical Staff, and any other Individual named as a Principal Investigator on a proposal, contract or an award.)
  • All Individuals involved in the design, conduct or reporting of proposed or awarded research from a Public Health Services Agency (e.g., NIH).
  • Department and Center: Administrators and Administrative Professionals
  • Directorate: All members
  • All Directors and staff of the following:
    •     President and Director’s Office
    •     Director of Research Office
    •     Communications
    •     Development
    •    Finance & Accounting
    •    Grants and Contract Services
    •    Human Resources
    •    Procurement
    •    Office of Technology Transfer
  • Directors of:
    •     Environmental Health & Safety
    •     Facilities and Services
    •     Information Services
  • Administrative staff of Marine Operations
  • All members of ACECS

The Institution’s Training is also required immediately under the designated circumstances.

  • The Institution changes the Conflict of Interest and Conflict of Commitment policies in a manner that affects an Individual’s requirements
  • A Principal Investigator is new to the Institution
  • the Institution finds that an Individual is not in compliance with the Institution’s Financial Conflict of Interest policy or management plan.

*Training registration instructions:

» Individuals with WHOI email and LDAP password

» Individuals without WHOI email and LDAP password

Note about recently revised Conflict of Interest (COI) policy and new COI training requirement

A number of recent events highlighted risks to academic institution from inattention to conflicts of interest. We decided that WHOI’s COI policy required revision to incorporate changes in the NSF Conflict of Interest Grantee Standards and updated practices of other agencies (e.g., NIH).  WHOI’s General Counsel and the Director of Research worked with Staff Council to develop and revise the COI policy, and to determine the level of COI training and who should be trained. The revised Conflict of Interest (COI) policy and COI training requirement is the result of a review lasting more than a year and a half.

 In order to reduce potential conflicts of interest and commitment, it is critical that WHOI Investigators and Administrators know how to identify potential conflicts and bring them forward to the Advisory Committee on Ethics, Conflicts and Security (ACECS) for review. The leader in COI training is the organization CITI. Since most federal agencies and departments leave it up to individual institutions to establish and enforce their COI policies, WHOI looked for a widely accepted and comprehensive training program to provide up-to-date understanding of conflict definitions and issues.  The appropriate level of training was discussed at length both by the COI task force and at Staff Council. It was determined that the comprehensive approach based on Public Health Service (i.e. NIH) requirements would be the most protective for WHOI.

The CITI COI training for WHOI Investigators and administrators has 3 modules; the first is an overview of the other two modules. The second module on Financial Conflict of Interest (FCOI) is geared to the NIH grants because that agency has the clearest and most specific regulations. This module will be revised to be more WHOI-specific and to minimize reference to Public Health Service funding, but specifics about FCOI and reporting that are consistent with WHOI policy will remain. The third CITI module on Conflicts of Commitments, Conflicts of Conscience and Institutional Conflicts of Interest is general information relevant to all researchers and administrators at WHOI. To keep costs down, WHOI Initially adopted the CITI COI standard training, but we plan to customize the training for later this year.  (People who have taken the current CITI COI training do not need to take training for another 4 years. Training is required every 4 years.)

 If you have questions about the COI forms or training, please contact Chris Land (cland@whoi.edu) or Larry Madin (lmadin@whoi.edu).

Last updated: April 29, 2016