Conflicts of commitment (COC)

I was contacted by a company asking me to give a compensated consultation to some investors, is there any UA regulation about that?

University Employees whose FTE is 0.50 or greater, are required to disclose any activity that meets the definition of an Outside Commitment or Outside Employment by submitting a disclosure of Outside Commitment or Employment (COC form) via eDisclosure. University approval is required prior to full-time University Employees (0.50 FTE or greater) entering into an Outside Commitment or Outside Employment (regardless of whether or not compensated for the activity).

  • The Outside Commitment Decision Tree on our Disclosure Requirements webpage link may be of assistance to you in determining whether the activity meets the definition of an Outside Commitment. More information on Outside Activity can also be found on our website.

 

Additionally, as an Investigator, one of the requirements is disclosure of Outside Interests (Significant Financial, Significant Personal and Foreign Interests). You can find an overview of the Disclosure Requirements on our website including Disclosure Table resources which outlines the disclosure guidelines.

 

Consulting Agreements

Our website has information related to Consulting Agreements including a Consulting Agreement Addendum that the University developed as a resource that University employees can use as an addendum to any agreement that you sign or can be used as guidance on common issues that may arise in a consulting arrangement that may relate to your university employment. 

What is Scientific Overlap?

NIH describes Scientific Overlap as: "Scientific Overlap occurs when substantially similar research is proposed in more than one application or is submitted to two or more different funding sources for review and funding consideration; or a specific research objective and the experimental design for accomplishing that objective are the same or closely related in two or more applications or awards, regardless of funding source."

What is Significant Use of University Resources?

“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.

What are the COI and COC requirements during the pre-award stage?

At the time of proposal submission to a federal funding agency, Investigators must have an up-to-date COI certification.  That means each Investigator has:

1.    Submitted either an Annual Disclosure Certification or a Research Certification in the last 364 days, and
2.    Does not have any changes to an existing Outside Interest or new Outside Interest.
 

How are Conflict of Interest and Conflict of Commitment related?

Conflict of interest (COI) and conflict of commitment (COC) reviews are separate because COI relates to bias in decisions and COC relates to a University employee's time & effort for UArizona, UArizona resources and UArizona Assets.

Sponsors & funders have identified the following concerns: 

1.    conflicts of interest
2.    shadow labs
3.    loss of Intellectual Property
4.    conflicts of commitment, including theft of time, resources and assets
 

New, Consolidated Disclosure System Now Available

3 years 3 months ago

eDisclosure is now available for conflict of interest (COI) submissions—annual disclosures and research certifications—and conflict of commitment (COC) form submissions.

For information on using eDisclosure, the following options are available:

Video Demos and Instructional Material: eDisclosure Information (NetID required)

Zoom Drop-In Training Sessions: eDisclosure Training (No registration required)
 
  • Thursday, July 1 – 11 am; 11:30 am; 12 pm
  • Thursday, July 8 – 11 am; 11:30 am; 12 pm

How will the move to eDisclosure affect you?

eDisclosure will be used for all conflict of interest and commitment disclosures.

All Full-Time University Employees (0.50 FTE or greater) must disclose:

  • Outside Employment
  • Outside Commitments
  • 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.

For research Investigators, notices for submission of Research Certifications will be issued on July 1. Notifications for submission of Annual Certifications will be issued by college/center, beginning July 12. Your college/center leadership will receive information related to additional eDisclosure training opportunities.

Reminder:  The University of Arizona is implementing a new Conflicts of Interest & Commitment Policy. Investigators will be required to complete an updated version of the COI Required Disclosure Training.

For questions or more information, contact the Office for Responsible Outside Interests at coi@arizona.edu or at 520-626-6406. For questions about Substantial Interests, contact Ted Nasser at enasser@arizona.edu or at 520-621-5449.

Implementing a New, Faster Conflict of Interest System

3 years 4 months ago

The Conflict of Interest (COI) Program will launch a new system, eDisclosure, designed to make submitting COC Forms (Requests for Approval of Outside Employment and Commitments) easier and faster. For more information about the implementation process, please visit RII’s New Systems Information webpage.

Please note the following important dates in the implementation process:

  • June 11, 2021 - Last day to submit disclosures, research certifications, and COC Forms in the current system.
  • June 12 - 30, 2021 - Blackout period (No COI or COC system will be available for submissions.)
  • July 1, 2021 - eDisclosure available (For your first disclosure or certification in eDisclosure, you will need to disclose all entities, including those previously disclosed in the legacy COI Disclosure System.)

How will this affect you?

The new system is relevant to full-time University Employees who are employed or have a professional commitment outside of the University. Please visit the COI webpage to learn more about who should submit a COC form. 

Please also note that beginning July 1, the Conflict of Interest Program will be called the Office for Responsible Outside Interests to more closely focus on the program’s goal: to align outside interests with the University’s mission to disseminate knowledge through teaching, research, and public service in a way that ensures transparency, integrity and public trust.

For questions or more information, contact the COI Program at coi@arizona.edu or at (520) 626-8266.