Office for Responsible Outside Interests

Why do I have to disclose my Outside Employment and Outside Commitments to the Office for Responsible Outside Interests?

The University requires that all Investigators (regardless of their U of A FTE) and all University Employees with a 0.50 FTE or greater submit an Outside Commitment, Outside Employment or Other Support form in eDisclosure for review because the University has a fiduciary responsibility to ensure that inappropriate external influences outside the course and scope of one’s University employment or research activities do not affect the performance of one’s primary duties to the University.

What happens if someone who is participating in a Research Project funded by the PHS/NIH does not comply with the Conflicts of Interest & Commitment Policy?

In accord with PHS/NIH policy (42 CFR § 50.605(3)), a retrospective review will be conducted if the Office for Responsible Outside Interests determines that an Investigator participating in any University project funded by the PHS/NIH (excluding Phase I SBIR/STTR grants) has not (a) complied with this Policy; or (b) complied with a required FCOI management plan; or (c) disclosed a SFI or SPI in a timely manner to allow appropriate review and management.

Does the public have access to conflict of interest information?

For Research Projects funded by PHS/NIH agencies, excluding Phase I SBIR/STTR grants, the University is required to respond within five (5) business days of receipt of a written request from a member of the public for information regarding determination of an FCOI of senior/key personnel for the funded project. Such public requests must comply with the requirements of 42 CFR § 50.605(a)(5) and 45 CFR § 94.5(a)(5) of the NIH grants policy.

Pursuant to A.R.S. § 38-509, all disclosures of Substantial Interests, as defined by A.R.S. § 38-502, are available for public inspection.