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COI Requirements at Proposal Submission

All Investigators participating in federally funded research activities, including sub-federal awards, must have submitted a disclosure within the past 364 days prior to the submission of any federal or sub-federal proposal, even if they have yet to participate in research activities.  (A disclosure can be any of the following:  Annual Disclosure Certification, Research Certification or an Update.) OROI will verify that all PIs, Co-PIs, Senior/Key Personnel and COI Disclosers ("Investigators") have an up-to-date disclosure at the time of proposal submission to a federal funding agency.

While this has been both a federal and UArizona requirement since 2012, the purpose of this process change is to ensure UArizona has appropriate documentation confirming compliance with this federal regulation.  This process change will not create a new COI requirement for Investigators.

Review Process

OROI will review COI statuses in the order received.  A "compliant" COI status means that the Investigator's COI disclosure will be up-to-date at the proposal submission deadline (i.e., a certification that has been submitted within the previous 365 days).  More specifically, OROI will:

  • Check the COI status for each Investigator, and
  • Disposition the request for approval 
    • If all Investigators are COMPLIANT, OROI will approve.
    • If 1 Investigator, or more, is NON-COMPLIANT, OROI will send a list of non-compliant Investigators to the PI, Proposal Initiator, and the non-compliant Investigator(s) via an email from >  In keeping with SPS’s Three-Day Deadline, OROI will return the proposal to the Proposal Initiator 3 business days prior to the federal funding agency's proposal submission deadline if an Investigator is not compliant by SPS's deadline.  

Communications to Investigators

OROI’s goal, is to help Investigators avoid scenarios in which a proposal cannot be submitted to a federal funding agency because they have not submitted a disclosure within the previous 364 days.  As such, we send multiple notifications to Investigators.  Here is an overview of the automated communications that are being sent directly to Investigators:

  • eDisclosure automatically sends a notification to individuals upon creation of an Annual Disclosure Certification.
    • An Annual Disclosure Certification is automatically created for (1) new employees who have a Faculty, Post Doc or Administrator ABOR code and (2) individuals who previously submitted a certification in eDisclosure but have not submitted one in the past 364 days.
    • If an Annual Disclosure Certification is not automatically created for someone, please contact to have a certification created.
  • eDisclosure automatically sends a notification to individuals upon creation of a Research Certification for a sponsored project.
    • These Research Certifications are created 60 days prior to the requested project start date.
      • Submission of a Research Certification counts as an annual disclosure unless the individual only uses the “Submit Certification with No Changes” activity.  This is because this activity is designed to allow individuals who have indicated that they do not have any Outside Interests to bypass the full certification process.  Thus, this activity does not qualify as an annual disclosure because the individual is not required to re-certify their full disclosure during the process.
  • UAccess Analytics notifications to individuals whose COI Requirement Status is “Incomplete” in the eDisclosure COI Requirement Status Dashboard.


Resources for Campus to Check COI Compliance

The eDisclosure Dashboards in UAccess Analytics capture and analyze information from eDisclosure to provide status information. 

The Conflict of Interest Requirement Status page provides Investigator-specific status information.  An individual’s “COI Requirement Status” will be Complete when they have completed the following:

  1. Completed the Conflict of Interest Required Training after July 1, 2021, and 
  2. Submitted a certification in the last 364 days. The certification can be an Annual Disclosure Certification, Research Certification or an Update.

Use the "Discloser Is Involved in Research?" filter to limit results to individuals who answered yes to the prompt "Are you directly or indirectly involved in any research at UArizona?"

The eDisclosure Proposal Development Status page provides Conflict of Interest compliance status information for Investigators associated with a specific proposal in UAccess Research.  A proposal will be in this dashboard 1 business day after the proposal development document is saved in UAccess Research. The Conflict of Interest compliance status in this dashboard may be delayed up to 2 business days.

If you are not able to access the dashboards, please submit a request using the UAccess Access Provisioning Tool, AccessFlow.

For questions about COI at Proposal Submission, please contact Ismael Jaimez at

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