Conflicts of interest (COI)

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."

eIRB and eDisclosure Unavailable April 21-23

1 year 6 months ago

The Research, Innovation & Impact Human Subjects Protection Program (HSPP) will implement upgrades to the electronic Institutional Review Board (eIRB) system to provide the latest features and maintain quality performance.

This upgrade will cause the eIRB and eDisclosure systems to be unavailable beginning 8 a.m., Friday, April 21 through 8 a.m., Monday, April 24.

eIRB

  • During the upgrade period, eIRB review and approval will be unavailable.
  • Submissions to the eIRB should be processed before 8 a.m., Friday, April 21, or after 8 a.m., Monday, April 24.
  •  
  • For urgent eIRB matters and just-in-time (JIT) requests that arise during this window: email Christine Melton-Lopez, director HSPP. 
  • For questions or more information: email the HSPP team.

eDisclosure

  • During the upgrade period, individuals will be unable to disclose Outside Interests, Outside Activity and Substantial Interests. Individuals will not be able to submit Research Certifications and Outside Activity approval will not be available.
  • Conflict of Interest (COI) at Proposal Submission: for federal and sub-federal proposals due on or before Wednesday, April 26, investigators are encouraged to complete annual disclosures before 6 p.m., Thursday, April 20.
  • For routing proposals received during the upgrade period, the Office for Responsible Outside Interests (OROI) will rely on data from Thursday, April 20. Beginning 8 a.m., Monday, April 24, OROI will return to using live data.
  • UAccess Analytics dashboards: the eDisclosure Conflict of Interest dashboards will reflect data from Thursday, April 20 until Tuesday, April 25.

 

What are the Conflict of Interest requirements for Investigators?

Investigators must:

1.    Complete the Required COI Disclosure Training after July 1, 2021.
2.    Complete the Required COI Disclosure Training once every 4 years thereafter.
Note:  OROI may direct an Investigator to complete the training more frequently.
3.    Submit an annual certification.  This can be an Annual Disclosure Certification or Research Certification.
4.    Update their certification within 30 days of a change to an existing Outside Interest.
5.    Update their certification within 30 days of acquiring a new Outside Interest.
6.    Submit a Research Certification for all non-sponsored and sponsored Research.
 

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.
 

"Why do I have to include an entity that is not an Outside Commitment in my disclosure?"

In the past, University Employees were asked to disclose Outside Commitments in the COC database and Outside Interests in the COI database.

The Conflicts of Interest & Commitment Policy incorporated and replaced the following policies:

1.    Conflict of Commitment Policy
2.    Conflict of Interest (UHAP) Policy
3.    Conflict of Interest in Purchasing Policy
4.    Individual Conflict of Interest in Research Policy
5.    Institutional Conflict of Interest Policy

Now, eDisclosure serves as a single platform to meet all policy disclosure requirements.
 

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