Approvers' Guidance

Who signs?

Every CoI disclosure needs to have a "Level 1 signer".This should be the direct supervisor of the disclosing individual.For faculty, the division chief, department chair, or designee should be assigned this responsibility.
Level 2 signers are required for all researchers who have significant financial interests to disclose.The level 2 signer for faculty should be as follows:
- SOM: Mary Stenzel Poore (designee for Mark Richardson)
- Research Centers & Institutes: Dana Director (designee for Dan Dorsa)
- SOD: Gary Chiodo
- SON: Lillian Nail
Multiple Level 1 and Level 2 signers may be entered, if more than one person needs to review, however, only one of each are required.

For both signatures levels, when signing the form in eCoI, you will note a checkbox to indicate if a management plan is needed.The management plan should be developed and discussed with the disclosing employee.
- At this time there is not a place in the eCoI system to upload or document the plan in full, but there is space for comments if you would like to make any management plan notes.
If the disclosing employee has not provided enough information in his/her disclosure form, you may also return the form to the employee by using the "return" button, providing your instructions for revisions in the comments box.

Level 1 signers: review entire form for thoroughness and any CoI concerns.
- Outside activities are approved by you.You determine if the activity is approvable and if a management plan is needed (see guidance below)
- Purchasing conflicts.For any financial interests listed that may be related to an individual's oversight in purchasing decisions, you determine the appropriate management plan.
- Research disclosures: You may provide input regarding the management plan.Disclosures related to research are reviewed and approved by the Conflict of Interest in Research Committee or the Committee Chair.
Level 2 signers (Research only):
- You may provide input regarding the management plan.Disclosures related to research are reviewed and approved by the Conflict of Interest in Research Committee or the Committee Chair.

As noted in the OA Approving Instructions, some outside activities require approval by the Provost or Chief Administrative Officer. At this time there is no electronic approval mechanism within eCoI for this additional review. Therefore, the department approver should discuss the outside activity and potential management plan with the Provost or Chief Administrative Officer, as appropriate.
For potential Conflicts of Interest in Research (CoIR), the CoIR committee reviews the disclosure. See more information about the CoIR committee review and management options.
For those who serve on standing purchasing committees such as the Value Analysis Committees and the Pharmacy and Therapeutics Committee, the committee chair or appropriate OHSU Logistics or Pharmacy official will determine appropriate management for any disclosed conflicts, as described in the Conflict of Interest policy
The Integrity Office also reviews disclosures by OHSU Executives, as described in the Institutional Conflict of Interest policy