Commonly Asked Questions

As per the conflict of interest policy at your organization, you hold one of the roles that require participation in this annual disclosure process. You can visit the following website to access the policy that relates to your organization(s):
Conflict of Interest and Professional Integrity Policies

You are required to complete a survey if you are a member of one or more of the following affiliates and have a specified role:

Northwestern University Feinberg School of Medicine (Feinberg):

• Full-Time Faculty (Regular and Research)
• Part-Time Faculty (Regular and Research)
• Contributed Services, Health System Clinician, and Regular-Lecturer Faculty
• Other Faculty (Adjunct, Emeritus, or Co-Terminus, if also an NMG physician/consultant or NMH Medical Staff)

Northwestern Memorial HealthCare (NMHC):

• Board Members (current and former) - for 990-related purposes
• Board Committee Members - for 990-related purposes
• Corporate Officers (current and former) - for 990-related purposes
• Highly Compensated (current and former) - for 990-related purposes
• Senior Leadership and Key Employees - for 990-related purposes
• Management
• Physician/Members
• Physician/Consultants
• Physician/Employees
• Other Decision Makers (Case Management/Social Work, Purchasing/Materials Management, Pharmacy Staff)
• Department Chairs, Division Chiefs, Medical Directors
• Medical Staff (non-employees and NMPG employees)
• Health Professional/Doctoral Level Staff
• Advanced Practice Providers (affiliated with NMHC, NMG, or NMPG)
• Purchasing-related Committee Members and Invitees (for the P&T committees and the Medical Device committees/sub-committees)

Children’s Hospital of Chicago Medical Center (Lurie Children's):

• Board Members (current and former) - for 990-related purposes
• Board Committee Members - for 990-related purposes
• Corporate Officers (current and former) - for 990-related purposes
• Highly Compensated (current and former) - for 990-related purposes
• Senior Leadership
• Senior Management
• Other Management
• Department Chairs, Division Heads, Medical Directors
• Medical Staff (those in Practice Plans and Community Based)
• Health Professional/Doctoral Level Staff
• Advanced Practice Providers
• Purchasing-related Committee Members and Invitees (for the Product Valuation and P&T committees)

The Shirley Ryan AbilityLab:

• Physical Medicine & Rehabilitation Department

The instructions for logging into the survey site will be distributed to all survey participants via email on February 1, 2024.

The survey site will be activated on the same day, February 1st, and can be found by clicking on this link: eDisclosure.

eDisclosure is the single disclosure system for the University community for all COI requirements, including research-related and the annual faculty and staff disclosure requirements.

For faculty disclosers, individuals should send an email to disclosure@northwestern.edu indicating the name and email address of the person they would like to assign as a proxy.  For example, I would like to assign Jane Doe at jdoe@northwestern.edu as my proxy for the COI survey process. The email must be received from the disclosers authorized FSM email address, if applicable.  Please note that the discloser is still required to complete the attestation.

In the past, Feinberg, Northwestern Memorial HealthCare (NMHC), Children’s Hospital of Chicago Medical Center (Lurie Children's), and the Shirley Ryan AbilityLab surveyed independently and at different times of the year with different tools, questions, and timeframes for reporting. Many of our faculty also received up to four separate surveys. The result was varied completion rates, confusion, and frustration. A steering committee, comprised of individuals from the three affiliates was created and worked to design and implement a joint survey tool. Feinberg is the affiliate that administers the survey on behalf of the other entities (NMHC and its subsidiaries). Lurie Children's joined our survey efforts in 2010 and the Shirley Ryan AbilityLab (formerly RIC) joined in 2011. Leadership from all entities reviews their corresponding survey participants' disclosures.

The types of questions you receive depend on your position/role within each affiliate. Possible question categories include:

• Service on Boards of Directors and Other Fiduciary Relationships (Self and Immediate Family Members)
• Ownership or Investment Interests (Self and Immediate Family Members)
• Compensated / Non-Compensated Activities
  
  • Industry Relationships (Self and Immediate Family Members)
  • Travel – Sponsored or Reimbursed (Self and Immediate Family Members, if NU Researcher)
  • Expert Witness Testimony/Legal Consulting (Self and Immediate Family Members, if NU Researcher)
  • Royalty Payments and Inventor Share (Self and Immediate Family Members, if NU Researcher)
• Participation in Purchasing Decisions
• Referrals and External Health Care Services
• Receipt of Gifts or Favors
• Use of Trainees
• Research / Research Compensation
• Time Commitment
• Inventions / Licensing of Inventions
• University Grant or Assistance Selection
• IRS Tax Form 990-Related
• Other Activities

Example of when to enter compensation in aggregate form:

As an editor of a journal, you receive a monthly stipend of $1,000. Rather than entering 12 line items of $1,000 each, you enter $12,000 and a date of 12/31/2023 when completing your annual disclosure survey on February 1, 2024. As an annual discloser, it is more efficient to enter the compensation you received within the 2023 calendar year in one lump sum.

Example of when to enter compensation in per event form:

As a speaker for Baxter, on February 1, 2024 you complete your annual disclosure and enter the following information regarding your relationship with Baxter:

• Speaking - 01/02/2023 - $1,000
• Speaking - 02/06/2023 - $2,000
• Speaking - 02/27/2023 -$1,000
• Speaking - 03/05/2023 - $2,000

If you received a recent payment, rather than having to recalculate the total compensation, you are able to add a new line item with the event payment. As a researcher or transactional discloser, entering compensation you received within the calendar year in per event form is advantageous when it comes time for you to complete your 2024 annual disclosure. Also, when it comes time for your 2024 annual disclosure to be reviewed, reporting compensation in per event form allows the reviewer to see only the information regarding the current timeframe up for review.

Survey questions relate to activities and relationships in the prior calendar year, in this case 2023.

The survey will be distributed via email on February 1, 2024; the survey deadline is February 29, 2024.

Failure to complete the survey by the deadline may result in your name being given to the Feinberg Vice Dean for Regulatory Affairs, the NMHC Chief Integrity Executive, the Lurie Children's Director of Compliance, and/or the Shirley Ryan AbilityLab Director of Compliance. Specific steps for non-compliant physicians are outlined in the Joint Affiliate Annual Disclosure Survey - Submission Process Flows, which can be accessed here: Conflict of Interest and Professional Integrity Policies

Yes, you will need to disclose amounts that you earned from each compensated relationship. Please note, no reporting threshold exists; all compensation, however small or large, must be reported.

Your tax records or other documentation of compensation may be helpful, as you will need to disclose amounts earned from compensated activities.

Yes. If you hold a full-time, part-time, or contributed services appointment at Feinberg, much of the information gathered in the survey will be posted on the Feinberg website for viewing by patients and the public in general. This information will be displayed under the "External Professional Relationships" section of your faculty profile. Search faculty profiles. Northwestern Medicine also includes a link to these profiles on their physician finder website.

We will list the following information (if applicable to you): (i) your industry relationships (which include consulting and related activities, ownership or investment interests, and royalty payments and inventor share); and, (ii) your service on boards of directors. We will only list the names of the entities with which you have relationships, not the compensation you have received from them. We will, however, note if the relationship was “voluntary/non-compensated.”

Summer 2024 for the 2024 Joint Affiliate Annual Disclosure Survey.

For Feinberg Faculty who have multiple roles, a joint review process has been implemented, whereby disclosures are examined at three levels - by your division chief (when applicable), by your department chair, and by joint affiliate leadership. Disclosures related to research are also forwarded to the Feinberg Conflict of Interest Committee for further review and consideration.

In 2010, the Feinberg disclosure policy was extended to cover contributed services faculty. That same year, Northwestern Medical Group (NMG) expanded its Conflict of Interest Policy to include Physician Consultants and Feinberg changed its policy to align more with the policies of its affiliate institutions. Additionally, Lurie Children's created their Disclosure and Management of Outside Activities Policy. In 2012, the Feinberg policy was updated to incorporate changes that Northwestern University implemented to comply with recently promulgated regulations from the Department of Health and Human Services, i.e. the Final Rule. Most recently, consistent with the final rule, excluded from disclosure requirements are activities related to and/or compensation received relative to lectures, seminars, teaching engagements, or service on advisory committees or review panels relating to federal, state, or local government agencies, an institution of higher education as defined in 20 U.S.C. 1001(a), an academic teaching hospital, a medical center, or a research institute that is affiliated with an institution of higher education. NMHC’s Gifts and Business Courtesies Policy was also updated in 2012. Updated policies will be provided here as they are made available: Conflict of Interest and Professional Integrity Policies

You may contact the Joint Affiliate Annual Disclosure Survey Administration Team:

Email: disclosure@northwestern.edu
Phone: 312-503-7878