Identifying conflicts through rigorous, consistent review of annual disclosures.

In addition to the annual disclosure period, the COI disclosure needs to be updated within 30 days of a change, addition, or elimination. For all new employees who are required to submit a COI disclosure, it must be completed within 60 days of your start date. 

CU Denver | Anschutz has a “Zero Dollar Threshold” - this means outside activities that reasonably relate to one's university duties must be disclosed, even if there is no compensation or remuneration for the activity. This includes all activities and collaborations, paid and unpaid, involving foreign governments, foreign universities, foreign talent recruitment, or similar programs. 

Covered individuals are required to submit a COI Disclosure annually during the fall collection period and thereafter as required by policy as listed below:

1. For grant personnel, the COI Disclosure is due before a grant proposal may be sent to applicable sponsors (per Office of Grants and Contracts policy)
2. For protocol personnel, the COI Disclosure is due before an IRB protocol submission (initial, applicable amendment or continuing review) will be reviewed (per IRB policy);
3. For personnel hired or promoted into an applicable job code after July 18, 2025, the COI Disclosure is due within 60 days of the hire or job change date  unless required to submit earlier due to a grant or protocol (see 1 and 2 above); 
4. For all other covered individuals (not included above), the COI Disclosure is due October 31, 2025. 
   

Please note that this COI Disclosure does not substitute for conflict of interest disclosures that may be required by affiliated hospitals (e.g., UCHealth, Denver Health), nor do affiliate hospital conflict of interest disclosures substitute for this COI Disclosure.

To disclose sponsored or reimbursed travel expenses, complete the Travel Disclosure Form.