Investigator Training & Disclosure Requirements

Identifying an Investigator

An Investigator is defined by the University of Arizona’s Conflicts of Interest & Commitment Policy as:

"any person who shares the responsibility of Conducting Research. This includes, but is not limited to, the Principal Investigator (PI), Co-PI, Co-Investigator, Project Director (PD), Co-PD, Senior/Key Personnel, and any other person, regardless of title or position, who is responsible for Conducting Research performed by or under the auspices of the University."

Investigator Training Requirements

Training for University employees is here: Conflict of Interest Required Disclosure Training.

    • Investigators must update training every four (4) years after initial training is completed.
    • All Investigators may be asked to update training earlier than four (4) years in the event that the University revises training in a significant enough manner as to require campus-wide re-training.
    • Individual Investigators may be asked to updated training earlier than four (4) years in the event that the Investigator is found to be noncompliant with the University’s Individual Conflict of Interest in Research Policy.

Investigator Disclosure Requirements

Disclosures for individuals with UA NetIDs and Password are completed using eDisclosure.  Instructions for completing the disclosure are provided here.

When must Disclosures be submitted:

  • All Investigators who will participate in research activities, either funded or non-funded, and including any human subjects research, at the University must complete a disclosure prior to participating in any research activities.
  • All Investigators participating in federally funded research activities, including sub-federal awards, must complete an initial disclosure prior to the submission of any federal or sub-federal proposal, even if they have yet to participate in research activities.  Investigators who have participated in research activities must ensure that they have an up-to-date disclosure at the time of submission to a federal funding agency (i.e., submitted a certification in the past 365 days).

When must Disclosures be updated:

  • Annually
  • Within thirty (30) days of acquiring a new Outside Interest or a change in an existing Outside Interest.
  • A Research Certification must be submitted for all non-sponsored and sponsored research.

What must be disclosed:

1.  Foreign Interests

  • Participation in a foreign talent or similar-type program
  • All resources and other support, both domestic and foreign, for ongoing research projects, including those conducted at a different institution
  • In-kind contributions from domestic and foreign institutions or governments that support your research activities
  • Any payment, reimbursement, travel support or other compensation, of any amount, that you personally receive, or will personally receive, from a foreign entity

2.  Research and Research Projects which mean any organized program of scientific inquiry that involves a systematic investigation, study, or experiment designed to develop or contribute to generalizable knowledge that is performed at or under the auspices of the University. Research includes non-sponsored research, research fellowship and training programs, and research-related activities in undergraduate, graduate, and postdoctoral education.

3.  Significant Financial Interests from the preceding 12 months which means any one of the following interests, held by you or a member of your family.  All equity and compensation from an entity will be added together to determine if you meet the $5,000 threshold.

  • Any income from Intellectual Property rights, such as patents or copyrights
  • Any equity in a private company, regardless of value
  • Equity valued at $5,000 or more in a public company
  • Compensation of $5,000 or more.  This includes salary, consulting fees, honoraria, paid authorship, and other types of remuneration for services from an outside entity.  
  • PHS Researchers only: Disclose any reimbursed or sponsored travel related to your institutional responsibilities, regardless of the amount. 

Note:  Significant Financial Interests of an Investigator do not include the following interests, which do not need to be disclosed:

  • Salary, royalties, or other Remuneration paid by the University to a current University employee or appointee;
  • Payments made by the University in exchange for the transfer of intellectual property rights assigned to the University and from agreements by the University to share any royalties related to such rights;
  • Income from investment vehicles such as mutual funds and retirement accounts, as long as the Investigator does not directly control the investment decisions made by the investment managers within these funds or accounts; and
  • Income from seminars, lectures, teaching engagements, or service on advisory committees or review panels sponsored by (i) a government agency (federal, state, or local); or (ii) an institution of higher education as defined at 20 USC § 1001(a); or (iii) an academic teaching hospital, medical center, or research institute that is affiliated with an institution of higher education.

4.  Significant Personal Interests from the preceding 12 months which are are any managerial, professional, or fiduciary position you (or anyone in your immediate family) hold in any outside entity, whether or not you or your family is compensated. This can include officer, director, and board positions.

Non-UArizona Employees should visit

Information for Non-UA Subcontractor, Consultants and Collaborators



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