Foreign affiliations are defined as associations/relationships (e.g. conducting activity such as consulting engagements, research collaborations, appointments or titles, or teaching) with foreign institutions of higher education, foreign governments, foreign companies or foreign nationals.
Stock and equity valuation should be updated as follows:
Public Entity: Update at least annually, based on Annual Report or other public valuation
Non-Public Entity:
If original value is $4,999 or less, update within 30 days of value reaching $5,000 or more
If original value is $5,000 or more, update at least annually
The value of Equity is determined through reference to public prices or other reasonable measures of fair market value (e.g., assets - liabilities = value).
Stock in a public entity is valued based on Annual Reports and other public valuations.
Valuing stock in a private entity can be done various ways using methods such as valuation ratios, internal rates of return, comparative analysis and discounted cash flow analysis.
Stock and equity only need to be disclosed if they are an Investigator's Significant Financial Interest or a University Employees Substantial Interest.
A Significant Financial Interest includes:
Any equity in a private company, regardless of value
Equity valued at $5,000 or more in a public company
However, 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, do not require disclosure.
A Substantial Interest includes: The ownership of three percent or more of the shares of a corporation for profit, where the total annual income from dividends, including the value of stock dividends, from the corporation exceeds five percent of the total annual income of the employee.
On the Stock or Equity page in eDisclosure, there are two options for disclosing stock and equity:
“Significant Use of University Resources” includes but is not limited to: use of research funding; use of funding allocated for asynchronous or distance learning programs; use of telecommunication and data services beyond ordinary use; use of university computing resources; use of instructional design or media production services; access to and use of research equipment and facilities or production facilities; use of University Assets* such as paid employee time, proprietary information, intellectual property (such as patents, trademarks, and copyrights), logos, land and buildings.
The use of library resources, personal workstations, or personal computers are not typically construed as Significant Use of Board or University Resources.
*University Assets is fully defined in the University's Misuse of Assets Policy.
This depends on your UA role (whether an Employee, Administrator and/or Investigator – An complete overview of UA roles and Disclosure requirements can be found here)
If you are a UA employee whose FTE is 0.5 or greater, the definition of Outside Employment and Outside Commitment is included below for your review. The Outside Commitment Decision Tree may be of assistance when making the determination as to whether an activity requires disclosure. Additionally, the Disclosure Table resources provide an overview of the disclosure requirements.
Outside Employment refers to any employment relationship outside of the University requiring a time commitment.
Outside Commitments: (1) are professional and other activities that are related to a University Employee’s professional expertise, outside of their University duties and responsibilities; (2) are for the benefit of an external entity or individual and are not covered by a fully executed written agreement between the University and the external entity; and (3) require a time commitment. Outside Commitments include Outside Employment, independent contracts for consulting services, private consulting groups comprised of University Employees, volunteer/pro bono work, appointments at postsecondary educational institutions, and foreign components, as that term may be updated by the University’s Office for Responsible Outside Interests.
Also, please refer to the University’s TLA-100 The Intellectual Property Policy in case applicable.
An up-to-date COI disclosure (either an Annual Disclosure or Research Certification submitted within the last 364 days) is required at the time of proposal to a federal funding agency.
Additionally, Federal regulations prohibit expenditures on Awards until after the COI review process is complete. Our office desires to see all funded research go forward without delay.
Therefore, to avoid Award Holds, you are asked to submit Research Certifications early. Generally, Research Certifications are available in eDisclosure 60 days prior to the project start date listed in the Institutional Proposal. (For certain clinical trials, it may be fewer than 60 days) eDisclosure will send a notification to the Investigator as part of the UAccess Research/Sponsored Projects integration. If at any time you have been informed that any given project was not funded you would then advise sponsor@arizona.edu as soon as possible that the specific project will not be funded and no action is required for the Research Certification.
The Human Subjects Protection Program requires protocol personnel submit a Research Certification via eDisclosure for each project they are listed on in eIRB. For sponsored research, the Human Subjects Protection program has mapped IRB protocol roles to the sponsored project personnel categories. This mapping tool can be used to ensure protocol personnel complete Research Certifications: Investigator Mapping.
If you will be participating in research under the auspices of the University, you are required to complete the Required COI Disclosure Training through Edge Learning and submit a disclosure via via eDisclosure. These requirements apply to anyone who is an “Investigator” on a research project at the University (whether or not externally funded). “Investigator” is a defined term in the Conflicts of Interest and Commitment policy, and generally means “any person who shares the responsibility for the design, conduct, or reporting of Research” and may include students, postdocs and trainees.
More details can be found on the Conflict of Interest Requirements for Students, Postdocs and Trainees webpage.
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RII also believes that it was important to get feedback from Faculty Senate and other stakeholders. As such, the policy underwent multiple stakeholder reviews, including review by Faculty Senate and APPC. It was presented to the full Faculty Senate at its December 2, 2019, senate meeting and circulated to the Faculty Senate for review prior to implementation on an interim basis in May 2021. It was also discussed at a January 9, 2020 APPC meeting in which Taren Ellis Langford was present. (Please know that all suggestions and edits from APPC were incorporated into the final policy.)
Here is the full list of stakeholders who were provided a copy of the draft policy and invited to participate in the review, feedback and comment period:
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