1. Compliance
  2. Office for Responsible Outside Interests

Disclosure Requirements

Disclosure of Outside Interests, Foreign Interests, Institutional Financial Interests & Outside Activity

University Employees and University affiliates and associates, including Designated Campus Colleagues who Conduct Research at or under the auspices of the University, are responsible for making disclosures to the Responsible Outside Interests Resources.  More information about UArizona's disclosure requirements can be found in the Conflicts of Interest & Commitment Policy (interim).

Who must disclose?

All Full-Time University Employees must disclose:

  • Outside Commitments (0.50 FTE or greater)
  • Substantial Interest

University Administrators must disclose:

  • Institutional Interests
  • Outside Employment
  • Outside Commitments
  • Substantial Interests

Investigators* must disclose: 

  • Significant Financial Interests
  • Significant Personal Interests
  • Foreign Interests
  • Outside Employment
  • Outside Commitments
  • Substantial Interests

*Investigators who are University Administrators must also disclose Institutional Financial Interests.

What should I disclose in eDisclosure?

Please remember that COI Disclosures, except Foreign Interests, are also required for your relatives' interests. This table will be updated as federal regulations, state law and/or ABOR policies may be updated in the future.

Activity Type

 COI Disclosure COC Disclosure

Prior approval required if your UArizona FTE is 0.50 or greater

 No Disclosure Required
Outside Employment with Remuneration less than $5,000   x  
Outside Employment with Remuneration of $5,000 or more x x  
Outside Commitment with no Remuneration   x  
Outside Commitment with Remuneration less than $5,000   x  
Outside Commitment with Remuneration of $5,000 or more x x  
Editorial compensation of less than $5,000  

x

Only if Outside Commitment

  
Editorial compensation of $5,000 or more x

x

Only if Outside Commitment

  
Managerial, professional or Fiduciary Position (even if not compensated) x

x

Only if Outside Commitment

  
Equity (shares, ownership, stock options) private company (any value) x    
Equity (shares, ownership, stock options) public company valued at less than $5,000     x
Equity (shares, ownership, stock options) public company valued at $5,000 or more x    
Income from investment vehicles such as mutual funds and retirement accounts, as long as you do not directly control the investment decisions made by the investment managers within these funds or accounts     x
Consulting, advisory, or speakers bureau with no Remuneration  

x

Only if Outside Commitment

  
Consulting, advisory, or speakers bureau with Remuneration less than $5,000  

x

Only if Outside Commitment

  
Consulting, advisory, or speakers bureau with Remuneration of $5,000 or more x

x

Only if Outside Commitment

  
Intellectual Property rights (license / royalties of any amount paid directly to individual by an entity other than UArizona) x    
Remuneration (e.g., honoraria or other payments for services) or Reimbursements of less than $5,000 (excluding sponsored travel)  

x

Only if Outside Commitment

  
Remuneration (e.g., honoraria or other payments for services) or Reimbursements of $5,000 or more (excluding sponsored travel) x

x

Only if Outside Commitment

  
Sponsored or reimbursed travel of any amount

x

only if have PHS or Dept. of Energy Funding

    
Substantial Interest x    
Volunteer or pro-bono work that is unrelated to my professional expertise     x
In-kind contributions from domestic and foreign institutions or governments that support your research activities x    
All resources and other support, both domestic and foreign, for ongoing research projects, including those conducted at a different institution x    
Participation in a foreign talent or similar-type program x x  
Any payment, reimbursement, travel support or other compensation, of any amount, that you personally receive, or will personally receive, from a foreign entity x    

Foreign Components (The performance of any significant scientific element or segment of a project outside of the United States, either by the recipient or by a researcher employed by a foreign organization, whether or not grant funds are expended.)

Includes, but is not limited to, (1) the involvement of human subjects or animals, (2) extensive foreign travel by recipient project staff for the purpose of data collection, surveying, sampling, and similar activities, or (3) any activity of the recipient that may have an impact on U.S. foreign policy through involvement in the affairs or environment of a foreign country.

   x  

ABOR Policy 6-705

A University Employee may obtain outside employment or render professional services provided (1) it does not in any way interfere with the person's university duties and the outside employment is fully consistent with all rules promulgated by UArizona and ABOR. Thus, UArizona implemented the now repealed Conflict of Commitment Policy in 2014. The standards of that policy are embodied in the Conflicts of Interest & Commitment Policy.

Grant Fraud

UArizona has a fiduciary duty to steward federal funds and ensure they are not used for the benefit of a third party.

ARS 38-504

A public employee shall not use or attempt to use their official position to secure any valuable thing or benefit for the employee that would not ordinarily accrue to the employee in the performance of the employee's official duties if the thing or benefit is of such character as to manifest a substantial and improper influence on the employee with respect to the employee's duties. A violation is a criminal offense.

Non-Financial Conflicts of Interest

Outside Commitments must also be reviewed to protect UArizona's Research enterprise. "Researchers who get federal funding have to watch out for 2 kinds of conflict of interest: financial and non-financial."

In a non-financial conflict of interest, an individual faces conflicting obligations from multiple employers or other entities. For example, an individual may be required to improperly share information with, or withhold information from, an employer or funding agency, which threatens research security and integrity.""

42 CFR 50, Subpart F, Promoting Objectivity in Research (FCOI Regulation)

Public Health Services FCOI Regulation

200 CFR 200, Chapter IX(A) Conflict of Interest Policies

National Science Foundation Grantee Standards

FAL 2022-02

Department of Energy Interim Conflict of Interest Policy

Factors for Assessing Senior/Key Personnel Disclosures

Defense Advanced Research Projects Agency's Risk-Based Measures to Assess Potential Undue Foreign Influence, Conflicts of Interest or Conflicts of Commitment

FAR Subpart 9.5

Federal Acquisition Regulations - Organizational and Consultant Conflicts of Interest

Guidance for Implementing NSPM-33

"Recently, the federal government determined that disclosure requirements should be standardized across all funding agencies. It also indicated that federal funding agencies ""should require that recipient organizations instruct covered individuals on how to disclose information related to potential financial conflicts of interest, including but not limited to: private equity, venture, or other capital financing.

To ensure UArizona employees are in compliance with federal regulations and requirements, UArizona applied a single standard for disclosure to all Investigators in 2014 when it implemented the now repealed Individual Conflict of Interest in Research Policy. That same philosophy and the same thresholds are embodied in the Conflicts of Interest & Commitment Policy."

ARS 38-503

An employee of a public agency who has, or whose relative has, a substantial interest in any contract, sale, purchase or service to or decision of such public agency shall make known that interest in the official records of such public agency and shall refrain from voting upon or otherwise participating in any manner as an officer or employee in such contract, sale, purchase or decision. A violation is a criminal offense.

Foreign Influence

"Federally-funded researchers may face conflicts of interest if they receive funding or other benefits from foreign entities, which may be looking to gain access to that research."

ABOR Policy 3-901(A)

A regent or employee may not use or attempt to use his or her official position to secure any valuable thing or benefit that would not ordinarily accrue in the performance of his or her official duties, if the thing or benefit is of such character as to manifest a substantial and improper influence on the regent or employee.

ARS 38-504(C)

A public officer or employee shall not use or attempt to use the officer's or employee's official position to secure any valuable thing or valuable benefit for the officer or employee that would not ordinarily accrue to the officer or employee in the performance of the officer's or employee's official duties if the thing or benefit is of such character as to manifest a substantial and improper influence on the officer or employee with respect to the officer's or employee's duties.

FSM Policy 8.12.2

Reviewing & Accepting Gifts" Acceptance of some gifts are subject to Research Compliance review, including but not limited to: Conflict of Interest, Export Compliance and Human Subject.

ABOR 3-901(B)

The university must identify, on a case-by-case basis, individual and institutional conflicts of interest and conflicts of commitment that may arise as a result of the proposed transfer of intellectual property.

Activity Type

 COI Disclosure COC Disclosure

Prior approval required if your UArizona FTE is 0.50 or greater

 No Disclosure Required
A loan of any amount between a non-publicly traded entity (i.e., a private loan) and a University Administrator or their family member x    
A loan of any amount between a publicly traded entity (i.e., a commercial loan) and a University Administrator or their family member     x
UArizona's equity or similar interest in a publicly traded entity valued at more than $100,000 or any amount in a non-publicly traded for-profit entity x    
Gifts totaling $1 million or more, cumulatively x    
Substantial gifts, including in-kind gifts, received from an actual or potential commercial research sponsor or an individual or entity that owns or controls products being studied or tested as part of the Research x    
Donation and sponsorship funds x    
Any agreement with an external entity that includes the right for the University or a University Administrator or their family member to receive payments, royalties or other income from the commercial development or sale of an investigational product that is the subject of University Research x    
Ownership by the Arizona Board of Regents (ABOR), on behalf of the University, of a patent and/or other intellectual property right in or sponsorship of an investigational new drug (IND) or device (IDE) application with respect to any drug or device for which human subject Research will be conducted x

 

 

  

Consult this decision tree to determine if you must submit a COC form