What is Budgetary Overlap?
NIH describes Budgetary Overlap as: "Budgetary Overlap occurs when duplicate or equivalent budgetary items (e.g., equipment, salary) are requested in an application but are already provided by another source."
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 3 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.
- For questions about COI at proposal submission: email Ismael Jaimez.
- For urgent conflict of interest and conflict of commitment matters during the planned upgrade period: email Taren Ellis Langford.
- For questions about submitting a disclosure or what to disclose: contact Judi Lopez and Ann De Bellis at DisclosureHelp@list.arizona.edu.
- For other questions or more information, please contact OROI.
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
New, Consolidated Disclosure System Now Available
3 years 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.
REMINDER: Rollout of New Conflict of Interest/Commitment system
3 years 1 month ago
Implementing a New, Faster Conflict of Interest System
June 11 is the last day to submit Research Certifications and Annual Disclosures in the legacy COI Disclosure System.
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 all University Administrators who have an Outside Interest and all University Investigators. Please visit the COI Webpage to learn how to disclose to the University whether you have any significant financial interests or significant personal interests that may be related to your research or institutional responsibilities.
For more information about the implementation process, please visit RII’s New Systems Information webpage.
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.
Implementing a New, Faster Conflict of Interest System
3 years 1 month 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.