New Conflict of Interest (COI) and Outside Activities reporting system

Update: Jan. 6, 2020

It is now time for Covered Individuals to submit their 2020 Statement of Financial Interests and complete the new COI Training Module. Both must be completed on or before March 1.

Covered Individuals must complete a Statement even if they do not have any outside activities and/or financial interests to disclose. Please complete the brief COI Training Module prior to completing and submitting your 2020 Statement of Financial Interests.

This is the first year that the COI Office is using a new software system, called COI-SMART, for COI Training and Statement Submission. Due to the significant changes to the COI Statement, no data has been imported into COI-SMART. Statements must include outside activities and financial interests for 2019, anticipated outside activities and financial interests for 2020, including supporting documentation such as personal agreements and non-UTSW Faculty appointment letters. If you previously disclosed activities and interests, you received an email with a summary table of those outside activities and/or interests which can assist you in completing your 2020 Statement of Financial Interests. If you need another summary sent to you, please contact the COI Office at the number below.

If you disclose anticipated participation in outside activities, completion of your 2020 Statement will serve as your request for outside activities and no separate request needs to be made. The COI Office will facilitate supervisor approval of your outside activities.

Access your COI Training and 2020 Statement of Financial Interests. 

Please visit the COI website for more information.

If you have any questions, the COI Office can be reached via conflictofinterest@utsouthwestern.edu or by calling 214-648-5300.

The following email was sent campuswide on Dec. 11.

Dear Colleagues:

The appropriate disclosure and management of outside financial interests is vital to protecting UT Southwestern’s reputation for excellence and maintaining the public’s trust. To facilitate these important processes, we are pleased to announce the implementation of a new system, starting in January, to modernize and streamline our Conflict of Interest (COI) reporting capabilities.

The new system, called COI-SMART, was selected by a cross-functional team of UTSW faculty, administration, and staff in close collaboration with the Conflict of Interest Office. The system improves our ability to ensure that financial relationships do not:

  • Bias the design, conduct, or reporting of research.
  • Detract from teaching, research, clinical, or administrative responsibilities.
  • Influence the training of students or trainees.
  • Result in improper transfers of state resources.
  • Contribute to inappropriate financial or nonfinancial gain.

Faculty, staff, and other “covered individuals” who disclose their financial interests on an annual basis will find numerous benefits to the new COI-SMART system, including:

  • The combining of two systems – Outside Activities & Employment (OAE) and COI – into one, eliminating the need to submit to two different systems.
  • A single login process and improved off-site and mobile access.
  • A more intuitive interface that better follows COI policies, eliminates nonessential questions, and allows for better information capture to reduce the need for follow-up after statement submission.
  • A streamlined supervisor approval process for OAE requests.
  • Disclosure of financial interests in ranges rather than actual dollar amounts, minimizing the need for updates when financial interest values change during the year.
  • Integration with CMS Open Payments, allowing physicians to review their most recent CMS Open Payments reports prior to entering information in the system.

We expect the system to go live in early January 2020; no action is required until that time. To help all covered individuals prepare for entering their 2020 disclosures in the new system, each individual will receive a summary of their current COI Statement disclosures via email prior to the new system going live. All covered individuals must submit a Statement of Financial Interests, even if they have no financial interests to report. Also, as part of the new process, individuals will be asked to disclose all non-UTSW faculty appointments.

The time frame for submitting your COI Statement of Financial Interests will remain the same – all submissions are due by March 1, 2020. Please see policies ETH-104, ETH-105, ETH-304, RES-401, and EMP-158 in the UTSW Policy Library for additional COI information. If you have any questions or need further assistance, please contact the COI Office at 214-648-5300 or conflictofinterest@utsouthwestern.edu.

Maintaining comprehensive Conflict of Interest disclosures is an important institutional safeguard for UT Southwestern, and we are pleased to be launching a more efficient and effective system for COI management. We appreciate your diligence and support during this transition.

Sincerely,

W. P. Andrew Lee, M.D.
Executive Vice President for Academic Affairs and Provost
Dean, UT Southwestern Medical School 

Arnim E. Dontes, MBA
Executive Vice President for Business Affairs
UT Southwestern Medical Center