How to Disclose
The Outside Interest Disclosure process for Atrium Health is electronic and available on the link below. To login, type your wakehealth.edu or atriumhealth.org email and password.
What to Disclose?
Disclosure of outside professional activities and financial interests that relate to your institutional role(s) and responsibilities, regardless of value, is required at least annually by institutional policy. This information is captured via the electronic disclosure system known as Huron eCOI.
- Relationships, activities, and financial interests related to your work at Atrium Health (e.g. teaching, consulting, advising, speaking, research, editorials, service on committees/boards, fellowships, unrestricted gifts, etc.).
- Licensed intellectual property, license agreements, and/or royalties (e.g., patents, copyrights, and current/potential future royalties from such rights).
- Fiduciary services (e.g. officer or board member of an outside entity) whether paid or unpaid.
- Ownership or equity in a start-up company related to your work or Atrium Health, even if it is just "on paper" or worth nothing.
- Ownership or equity of outside entities (whether public or privately held) that do business with Atrium Health, in which you have day to day control of the investments.
- Family members’ outside interests with entities that do business with Atrium Health.
- Writing, membership on peer review panels, visiting professorships, or lectureships at academic medical centers, federal and non-federal study section membership, grant review panels, or textbook editorships.
- Service on NIH study sections or NSF grant review panels, or service on DSMBs or OSMBs for federal research projects.
- Mutual funds or other retirement investments in which you have no day-to-day control.
- Grants or sponsored research funding you have received while at Atrium Health that went through the Office of Sponsored Research.
Additional Disclosures Required Outside the Huron eCOI System
- Disclosure of project specific relationship with submission of grants, contracts and regulatory protocols.
- Disclosure of outside relationships when submitting requisitions to Institutional procurement committees.
- Disclosure of all financial interests by standing committee members to their committee(s).
- Public disclosure of outside interests for all publications (including news releases), presentations (including posters) and approved media contact related to an Individual’s outside relationship or financial interests.
- Disclosure of third party-paid information in Concur prior to sponsored professional travel.
Who is Required to Disclose?
- Leadership (Directors and above)
- Faculty and Providers
- Advance Practice Providers (NPs and PAs)
- Residents, Fellows and Graduate Students
- CRNAs and Specialty Nurses
- Optometrists, Chiropractors, Podiatrists and Dentists
- Mental Health Therapists and Social Workers
- Physical Therapists
- Other roles that can independently bill for patient care
When to Disclose?
Individuals are required to disclose during the annual online disclosure process which occurs in July or upon hire.
What if My Relationships Change?
Disclosures must be kept current. When substantial changes in external activities occur, individuals are required to update their disclosure within 30 days. Contact the COI Office at firstname.lastname@example.org to update your annual disclosure. The COI Office will send you instructions and the link to Huron eCOI.
What If I Fail to Disclose as Required by Policy?
Individuals have an obligation to comply with policy. Failure to disclose may result in the following repercussions:
- Reimbursement to the Institution for misused resources, including salary and/or other forms of institutional compensation and other applicable fines imposed by outside entities.
- Written admonition for placement in Individual’s employee file indicating that the individual’s good standing has come into question.
- Ineligibility to participate in grant applications, IRB, or IACUC applications, or on committees.
- Ineligibility to work with graduate students.
- Retrospective review of all research activity on your PHS funded project (methods, data, results and publications) to ensure that no bias has occurred, as required by federal regulation. This means all research activity must stop until the retrospective review is complete.
- Dismissal from an educational or training program.
- Performance improvement counseling.
- Dismissal of employment.