The review process:

Covered Individual submission of the Attestation and Disclosure Form (ADF), Compliance Helpline complaint, report or query.

COI Module automated sort of the ADFs for items of interest.

COI Analyst review of referred cases.

COI Analyst and Institutional Compliance Officer action (resolve or refer).

Convene Conflict Review Board (CRB), if required.

CRB recommends management plan to COI Office.

Institutional Compliance Officer decides action or directs an alternate management plan.

COI Office forwards approved management plan to the Covered Individual and Appropriate Authority for implementation.

• Designates a timeline for implementation.

• All elements of the plan put into practice.

• Appropriate Authority verifies back to COI Office that management plan put into practice.

Covered Individual may request reconsideration of the plan to the COI Office within ten working days.

Institutional Compliance Officer reconvenes CRB.

CRB resolves reconsideration request within fifteen business days.