Research Investigators

We need to submit disclosures for three subaward partners as part of a program. Does EACH subaward partner need to submit ONE disclosure or do ALL individuals from each subaward need to submit a disclosure?

All Investigators on each subaward will be required to complete the training and disclosure requirements. An Investigator means any person who shares the responsibility of Conducting Research. Conducting Research includes the design, development, testing, evaluation, conduct, reporting, review, and oversight of a program of scientific inquiry. Each Investigator will need to submit an individual disclosure.

What is a Financial Conflict of Interest?

Financial Conflict of Interest (FCOI) means an Outside Interest is Related to, or can be perceived to be Related to, an individual’s institutional responsibilities.

"I will only need to submit a COI when I am notified that the proposal will get funded, not while we are still waiting for a decision, correct?"

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.

Why do personnel on my IRB protocol have to submit a 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.

"I’ve agreed to be on an advisory board for the Oxford Dictionary of African American English. I’ll be given more than $5000 and this is my area of expertise. What do I need to do for COI or COC?"

If this activity meets the definition of an Outside Commitment, it should be disclosed for conflict of commitment review. The Outside Commitment Decision Tree on our Disclosure Requirements webpage may be of assistance in making this determination.

"I have been invited to participate in a small conference. The conference is funded by a grant and the grantee is reimbursing participants for travel expenses. Is this a COC/COI?"

There is not enough information to determine whether this should be disclosed for conflict of interest review. (e.g., Is it a UArizona grant? Are you funded by a PHS agency or the Dept of Energy?) Please contact OROI at coi@arizona.edu or visit our office hours (1st & 3rd Thursday, 2 pm – 3 pm; Connect via Zoom) for assistance.

"While on sabbatical, a foreign university wants to pay my travel and lodging costs (under5K) to work on a co-authored manuscript with a colleague at that university."

If you are an Investigator, this is a Foreign Interest that must be disclosed for conflict of interest review. Foreign Interests are:

"I have to fill out a conflict of interest form for every doctoral student for whom I am advisor when they submit an IRB. The questions asked on the form are not relevant for this situation. It's a waste of time and irrelevant."

Investigators, as defined in the Conflicts of Interest & Commitment policy, are required to submit a Research Certification for each Research Project, both non-sponsored and sponsored. OROI relies on the PI to make this determination. “Who is an Investigator?” can be used to help determine if you are an Investigator.

"Our research is applied work on the field, with communities, nonprofits, and other organizations. How do we determine what is a 'conflict'?"

University Employees are asked to disclose their Outside Interests (Significant Financial Interests, Significant Personal Interests, Foreign Interests), Outside Commitments and Substantial Interests so that determinations of what is and is not a conflict can made through OROI.

"What is research?"

Research and Research Project 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.

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