Submit a Disclosure

Financial Conflict of Interest (FCOI) disclosure requirements apply to all individuals involved in the design, conduct, or reporting of an externally funded research project.

Effective June 1, 2026, the Cayuse system replaces Axiom Mentor for all Financial Conflict of Interest (FCOI) submissions. For a visual overview of the new disclosure process, view the .

There are two types of required FCOI disclosures in Cayuse:

  • Annual Disclosure
  • Research-Based Disclosure

Annual Disclosure

The Annual Disclosure is a researcher’s comprehensive Financial Conflict of Interest (FCOI) record. It is used to disclose Significant Financial Interests (SFIs) or certify that no SFIs exist. Annual Disclosures must be renewed each calendar year by February 15, and updated within 30 days of acquiring or discovering a new SFI.

The Annual Disclosure:

  • Must be on file in Cayuse before a Research-Based Disclosure can be submitted for approval for a specific research project
  • Must be renewed each calendar year by February 15
  • Must be updated within 30 days of acquiring or discovering a new Significant Financial Interest

Information from a researcher’s most recent Annual Disclosure will automatically carry forward into the next Annual Disclosure, so only new information or changes need to be updated.

If a researcher plans to submit a new funding proposal between June 1 – December 31, 2026, they may either:

  • Complete the Annual Disclosure in Cayuse now to save time (see How to Submit an Annual Disclosure below), or
  • Wait until prompted to complete the Annual Disclosure during their next proposal submission. The Annual Disclosure must be on file in Cayuse before a Research-Based Disclosure can be submitted for approval for a specific research project.

You will need to complete the 2026 Annual Disclosure in Cayuse even if disclosures were previously made in Axiom Mentor during the 2026 calendar year. The Cayuse disclosure forms include improvements and questions that were not present in Axiom Mentor.

If a researcher will NOT submit a new funding proposal in 2026:

  • They may wait until the 2027 annual FCOI disclosure campaign (Jan 1 - Feb 15) to complete the Annual Disclosure in Cayuse.

  1. Log into the system
  2. Click your name in the top right corner of the page
  3. Select My Profile
  4. Click COI Disclosures from the left-hand menu
  5. Click the blue + New Disclosure button in the upper right corner
  6. Select Start a new Annual Disclosure and click Next
  7. Complete or update the form and submit

Researchers should submit a new Annual Disclosure if:

  • Their most recent Annual Disclosure was not submitted within the current calendar year, or
  • They need to update their Annual Disclosure due to changes in financial interests.

 

Research-Based Disclosure

The Research-Based Disclosure is a brief and one-time, project-specific disclosure completed for each externally funded research project prior to proposal submission. The Research-Based Disclosure is used only to confirm that a researcher’s Annual Disclosure is up to date and, if applicable, identify which SFI(s) recorded in the Annual Disclosure are related to the specific research project.

Before a Research-Based Disclosure can be submitted for approval for a specific project, researchers must ensure their Annual Disclosure is up to date in Cayuse.

There are two ways of completing a Research-Based Disclosure in Cayuse:

Automated Email Request from Cayuse
This is the most common way to complete a Research-Based Disclosure. When a new proposal application in Cayuse Sponsored Projects is completed and routed for review:

  1. The PI and all listed 一起草 key personnel will receive automated email requests from Cayuse to complete their Research-Based Disclosure for the project.
  2. Researchers can click the link provided in the Cayuse email notification to directly open their Cayuse COI Disclosure page.
  3. Select the disclosure associated with the proposal.
  4. Complete all required questions and submit.

Manual Submission by Researcher
In some situations, a researcher may need to submit a Research-Based Disclosure manually, without having received an email prompt from Cayuse as described above. For example, if new key personnel are added to a project after proposal routing, or if a researcher would like to complete their Research-Based Disclosure before the proposal is routed for review in Cayuse Sponsored Projects.

  1. Login to the  system
  2. Click your name in the top right corner of the page
  3. Select My Profile
  4. Click COI Disclosures from the left-hand menu
  5. Click the blue +New Disclosure button in the upper right corner
  6. Select Start a new Research-Based Disclosure and click Next
  7. Complete or update the form and submit

 

 

Common Questions

Legacy FCOI disclosure data from Axiom Mentor was not transferred into Cayuse. The Cayuse disclosure forms include improvements and questions that were not present in Axiom Mentor.

If you plan to submit a new funding proposal between June 1 - December 31, 2026:

  • You will need to complete the Annual Disclosure in Cayuse, even if disclosures were previously made in Axiom Mentor during the 2026 calendar year. You may either complete your Annual Disclosure in Cayuse now to save time, or you may wait until prompted to complete the Annual Disclosure during your next proposal submission. The Annual Disclosure must be on file in Cayuse before a Research-Based Disclosure can be submitted for approval for a specific research project.

If you do NOT plan to submit any new funding proposals in 2026:

  • You may wait until the 2027 Annual Disclosure Campaign (Jan 1 - Feb 15) to complete the Annual Disclosure in Cayuse.

Any individual responsible for the design, conduct, or reporting of an externally funded research project must submit the FCOI disclosure through Cayuse. Individuals required to submit FCOI disclosures are known as “Covered Individuals.”

  • Covered Individuals may include Principal Investigators (PIs), Co-Investigators, senior/key personnel, and any other individual (e.g. postdocs) responsible for the design, conduct, or reporting of the project, regardless of title or position.

This requirement applies regardless of whether the individual receives salary or any other form of compensation from the research project.

Researchers must complete the FCOI disclosure even if they have no Significant Financial Interests (SFIs) to disclose.

Researchers must maintain a current Annual Disclosure in Cayuse that provides information on all of their SFIs, or certifies that no SFIs exit.

  • Annual Disclosures must be renewed each calendar year by February 15 and updated within 30 days of acquiring or discovering a new Significant Financial Interest (SFI).

Prior to each new proposal submission, researchers must complete a brief and one-time, project-specific Research-Based Disclosure for each research project. This form will ask the researcher to confirm that their Annual Disclosure is up to date and, if applicable, identify which SFI(s) recorded in the Annual Disclosure are related to the research project.

  • Research-Based Disclosures must be completed before an externally funded proposal can be submitted for review and approval.

The Annual Disclosure is a researcher’s comprehensive Financial Conflict of Interest (FCOI) record. It is used to disclose Significant Financial Interests (SFIs) or certify that no SFIs exist. Annual Disclosures must be renewed each calendar year by February 15, and updated within 30 days of acquiring or discovering a new SFI.

The Research-Based Disclosure is a brief and one-time, project-specific disclosure completed for each externally funded research project. Rather than requiring researchers to re-enter all of their financial information for every proposal, the Research-Based Disclosure references the information already reported in the Annual Disclosure.

The Research-Based Disclosure is used to:

  • Confirm that the Annual Disclosure is current and accurate.
  • Identify, if applicable, whether any SFIs reported in the Annual Disclosure are related to the specific research project.

In short, the Annual Disclosure records a researcher’s financial interests, while the Research-Based Disclosure connects those interests to a specific externally funded research project.

The Annual Disclosure serves as a researcher's central record of Significant Financial Interests (SFIs).

The Research-Based Disclosure connects that information to a specific externally funded research project. This allows Research Integrity & Compliance (RIC) to determine whether any disclosed interests may represent a Financial Conflict of Interest for that particular project.

Together, these disclosures help ensure compliance with federal regulations, sponsor requirements, and 一起草 policy.

In addition to submitting an FCOI disclosure, any individual responsible for the design, conduct, or reporting of an externally funded research project must complete and maintain valid Conflicts of Interest training through CITI Program.

Completion of Conflicts of Interest training is required every 4 years.

For more information, visit the Training Requirements page.