COI - Disclosure Review Walkthrough

Overview

Once a reporter has submitted their disclosure there are several steps to the COI Review process. During this process a disclosure can be automatically assigned for review based on an institution's Unit Hierarchy, manually assigned to committee reviewers, returned to the reporter for additional clarification and ultimately approved.

Review Lifecycle of a Disclosure

Submission and Notification

Once a Disclosure is submitted for review a notification is sent to the COI Administrator alerting them that a new disclosure is ready for review. This notification can be configured by each institution. For more details on configuring the notifications listed below see the COI - Notifications article.

If a user has turned on the Automatically assign additional reviewers when disclosure is submitted, based on the reporter's primary unit setting then the disclosure will automatically be assigned to any COI Reviewers in their primary units, and all units above their primary unit in your institution's Unit Hierarchy. A notification will be sent to any automatically assigned reviewers.

Opening And Assigning Disclosure for Review

Each assigned reviewer and the COI Admin can access the disclosure via the Review Disclosures screen linked in the COI portal sidebar. For more information on how to use the filters in the Review Disclosures screen see the COI - Filters article.

Once the disclosure is opened the admin can assign additional manual reviewers using the Assign Reviewers button.

The Assign Reviewers screen will display any reviewers that were automatically assigned upon submission. If the admin begins typing in the field at the top of the screen they can select additional reviewers to add to the disclosure. Only individuals configured in the COI Reviewer role will return on this search. If additional reviewers are added to the disclosure this way they will receive the COI Disclosure Assigned for your Review notification shown above.

 

Commenting On a Disclosure

The COI Admin and any assigned COI Reviewers can now add comments to any question, Financial Entity or other List entry by clicking on the +Comment icon next to the field or list they wish to comment on.

The admin can make a comment and then make the comment visible to to the Reporter if the Send Back to Revise action is taken. They can also make comments visible to the Reviewer upon review assignment. Reviewers do not have access to comment permissions. They will always be able to view comments they made, but they cannot make their comments visible to other reviewers or the reporter. That access must be granted by a COI admin. The title of the comment box will be the regular Field Label of the gadget. If you have setup your gadgets to display Field Label Long, be sure your regular Field Label is descriptive enough to be a comment header. To see more about how to configure your COI Form gadgets see the Form Gadgets article.

Once a comment is added the Admin can modify the permissions or text by clicking on the comment icon and making changes to the visible sections or Edit comment option to change text. 

Once a comment is added to a question the comment field will appear with a number in the beginning noting how many comments are present in that particular section.

Dispositioning Projects

In addition to commenting the Admin and Reviewers can disposition each project, and each financial entity/project relationship in a disclosure listed in the disclosure. Reviewers can assign a recommended disposition, and the COI Admin can assign the final disposition. An Admin can also be assigned as a Reviewer if appropriate and can then document the final disposition as well as recommendations. Some institutions assign the Admin as a reviewer so they can record specific regulatory determinations in the reviewer recommended dispositions such as internally tracked relationship exemption categories. The COI Admin disposition will be visible to the researcher once the disclosure is approved.  The recommended dispositions will not be visible to the researcher.

Note: Once a Project Disposition is recorded by the Admin it will be immediately displayed in the Sponsored Programs modules. This allows the Admin to approve relatively simple projects immediately, even if the overall disclosure needs an extended review because of more complex project/entity relationships.

When a COI Administrator receives a new disclosure the system will highlight projects that need to have dispositions assigned. This is only highlighted for the Admin, not for reviewers since a reviewer may only need to review certain projects and we don't want to highlight projects that they may not be responsible for.

Completing Review

When the reviewer has entered all appropriate comments and recommended dispositions on the disclosure they will press the Complete Review button to submit their review to the COI Administrator.

After pressing the Complete Review button a notification will be sent to the COI Admin alerting them that the Review is complete.

The admin can make any of the reviewer comments visible to the reporter, or other reviewers. If needed they can send the disclosure back to the reporter for revision. For more details on completing a returned disclosure see the COI - Returning Disclosures for Revision article.

Final Approval

When the review process is complete the COI Administrator will approve the disclosure with the Approve button.

Depending on how your system is configured the COI Admin may be required to assign a disclosure level disposition to complete the Approval process. This dropdown will default to the highest level disposition (defined by the order in the system configuration) that has been assigned to a project.  This auto selection can be overridden.

After the COI Admin approves the disclosure a notification is sent to the reporter letting them know their disclosure has been approved.

Archiving/Inactivating a Disclosure

There may be times when a user leaves an institution (becomes inactive) or an active user no longer requires a disclosure because their participation in research has completed.  Within Kuali Research COI admins have the mechanism of filtering out inactive users via the User Active filter/column and also the ability to manually deactivate a disclosure via the Disclosure Active filter/column.  More information on this functionality can be found in the COI - Disclosure Archiving article.