Institutional CoI
Executive and Board Member Conflict of Interest Disclosures
What is an ICoI?
An institutional conflict of interest may exist when executives have an external relationship or financial interest in a company or organization that has significant business transactions with OHSU and thus may interfere, or appear to interfere, with the obligation to act in OHSU's best interest. Because the appearance of a conflict may be as damaging to the public trust as an actual conflict, potential conflicts must be disclosed, evaluated, and managed with the same thoroughness as actual conflicts. One example of an ICoI would be if an OHSU executive is a member of the scientific advisory board of a company that sponsors research at OHSU under the oversight of the executive.
Who is required to complete an executive ICoI disclosure?
OHSU Board of Directors Members or Executives, the President, Vice Presidents, Deans, and those who report to a Dean or Vice President, except support personnel must complete the ICoI disclosure.
What should be reported as an ICoI?
Significant financial interests related to OHSU activities and other potential conflicts of interest as described on the disclosure form and in the glossary of terms . The standard for these disclosures is “to the best of your knowledge”. There is no obligation to investigate or research your current business relationships or investments to discover interests of which you may not be currently aware.
When should an ICoI be disclosed?
Big Brain will send out annual reminders so that the disclosure may be completed by the indicated due date (usually July 30). If the responses to any of the questions change during the year, the form must be revised and resubmitted.
How do I complete the ICoI disclosure?
- The ICoI disclosure is now online as part of the new CoI module in the Big Brain education system. All OHSU executives should complete the CoI module in Big Brain and check “yes” to the question asking if he/she is an executive which will lead to the online disclosure form.
- By completing this module in Big Brain, the ICoI disclosure form will be submitted to the OHSU Integrity Office and reviewed by the Integrity Program Oversight Council if necessary.
- If you experience any problems completing the on-line form, please contact the Integrity Office at 503-494-8849.
Resources
- Policy: Institutional Conflicts of Interest, 10-01-021
- Disclosure Form: http://www.ohsu.edu/cc/ed/bb/
- Contact: OHSU Integrity Office – 503 494-8849


