Conflicts of interest (COI)

New, Consolidated Disclosure System Now Available

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)

Event Date
July 1, 2021
Last Updated
July 1, 2021

REMINDER: Rollout of New Conflict of Interest/Commitment system

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:

Event Date
June 4, 2021
Last Updated
June 4, 2021

New Systems Information for COI, COC, HSPP, and Proposals

Implementing New Systems to Make Your Work Easier

Beginning in summer 2021, the Office of Research, Innovation and Impact (RII) will sequentially roll out and upgrade new systems designed to make your work related to Conflict of Interest and Commitment matters, the Human Subjects Protection Program (HSPP), and research proposals much easier.

Latest Related Announcements:

[Complete] - UAccess Research (UAR) system update

This winter, following implementation of the COI and HSPP systems, the current UAccess Research (UAR) system will be updated to a newer version of the Kuali Research application.

Here are some highlights: 

  • The updated system will go live Jan. 25, 2022.
  • The University VPN will no longer be required to access the research system.
  • Proposal routing will eliminate lead unit pre-approval, routing immediately to investigators and department approvers simultaneously.
  • The research system will be unavailable from close of business on Jan. 20 until the morning of Jan. 25.
  • To prepare for routing changes, all proposals with deadlines from Jan. 18 to Jan. 28 must be fully approved and finalized in UAR by Sponsored Projects Services (SPS) before the UAR transition. Other proposals that began routing in the past can be canceled, copied and rerouted by the proposal initiator when the new UAR goes live. Additional details about proposal deadlines will follow.
  • Responses to proposal questions will flow from proposals through awards to facilitate more accurate campus and institutional reporting. 
  • The system will deliver new features and fixes on a continuous basis.
  • Familiar content will have a more modern look and feel.

For more information, contact Susan Mundt, SPCS assistant director of operations, at mundts@arizona.edu.

[Complete] Implementing a New Institutional Review Board (IRB) System

The Human Subjects Protection Program (HSPP) will launch a new system, eIRB, designed to make submitting human research protocols easier and faster.

Please note the following important dates in the implementation process:

  • Aug. 13 – Last day to submit to the HSPP for full committee review.
  • Aug. 20 – Last day to submit to the HSPP for non-committee review. Any submissions received by this date but not yet finalized or any submission received after this date may not be reviewed and will be returned to you with further instruction on how to proceed.
  • Aug. 25-Sept. 12 – Blackout period (No IRB system will be available for submissions).
  • Sept. 13 – eIRB is available to submit materials to the IRB.

How will this affect you?

The new system is relevant to all University employees and students who conduct research involving human subjects.

  • Please plan your submission to the HSPP with the above dates in mind.
  • If your existing project(s) is set to expire during the planned blackout period, please submit a renewal or closure paperwork to VPR-IRB@arizona.edu as soon as possible. The HSPP will prioritize renewal submissions to ensure approval does not lapse due to system down time.
  • For urgent matters and Just-in-Time (JIT) requests that arise during the planned blackout period, please contact Christine Melton-Lopez, Director HSPP, directly at melton1@arizona.edu.  

For questions or more information, please contact the HSPP at VPR-IRB@arizona.edu.

[Complete] New COI & COC system launched July 1, 2021!

How will this affect you?

The new system is relevant to individuals who submit COI disclosures and/or COC Forms (Requests for Approval of Outside Employment and Commitments):

  1. University research Investigators
  2. University Administrators who have an Outside Interest
  3. 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.

NEW COI & COC Policy:  The Conflicts of Interest & Commitment Policy (Interim) policy incorporates five of the University's conflict of interest and commitment policies into one policy to alleviate confusion and contradictions. A single conflict of commitment policy will now be applicable to full-time University employees. The policy is approved on an interim basis to address immediate concerns while the substantive policy revisions are presented for stakeholder feedback and publication.

Rollout of new Conflict of Interest, Human Subjects Protection Program, and Research administration systems

Implementing New Systems to Make Your Work Easier

Beginning this summer, the Office of Research, Innovation and Impact will sequentially roll out and upgrade new systems designed to make your work related to Conflict of Interest and Commitment matters, the Human Subjects Protection Program (HSPP), and research proposals much easier. Because these changes are relevant to all of campus, from students to staff to faculty, please check your email inboxes in the coming weeks and months for information about training sessions and transitioning to the new systems.

Event Date
May 6, 2021
Last Updated
May 6, 2021

Students, Postdocs & Trainees

Conflict of Interest Requirements for Students, Postdocs and Trainees

If you participate in research under the auspices of the University, you are required to comply with the University’s Conflicts of Interest & Commitment Policy.  Anyone who is an “Investigator” on a research project at the University (whether or not externally funded) must submit a Conflict of Interest disclosure.  “Investigator” is a defined term in the policy, and generally means “any person who shares the responsibility for the design, conduct, or reporting of Research.”  This may include students, postdocs and trainees.

In particular, you are required to periodically disclose to the University whether you have any significant financial interests or significant personal interests that may be related to your research.  You also must complete COI training once every four years. The COI Disclosure training course can be accessed through the EDGE Learning.

Your Annual Certification must be updated within 30 days of acquiring a new interest or changes to an existing interest, or at least annually.  Additionally, you must also submit a Research Certification for each non-sponsored and sponsored research project.

Message to the Public about Conflict of Interest and Research

Public Access to Information about Financial Conflict of Interest in a PHS-Funded Research Project

The Public Health Service (PHS) Rules on Financial Conflict of Interest require that, for research projects for which the PHS or the National Institutes of Health issues a Notice of Award or a notice of noncompeting continuation (with funding) on or after August 24, 2012, the public may request the following information on any Financial Conflict of Interest identified by the University for any senior/key personnel in the project:

  • the senior/key personnel name, title, and role in the research project; and
  • the name of entity in which the financial conflict of interest is held by the senior/key personnel; and
  • the nature of the financial conflict of interest and its approximate dollar value, which may be reported in specified dollar ranges.

[Relevant PHS regulations: 42 CFR 50.605(a)(5)(i) and 45 CFR 94.5(a)(5)(i)]

To request information on a financial conflict of interest, complete the Request for Report of Financial Conflict of Interest (FCOI) in Project Funded by US Public Health Services (PHS) form:

  1. Download the form;
  2. Enter the required information;
  3. Print the form;
  4. Sign and date a copy of the completed form; and
  5. Mail to the address specified.

The University will respond to a fully completed request form within five (5) business days of receipt by the University’s Office for Responsible Outside Interests.

Federal Regulations for Conflict of Interest

Public Health Service (PHS) Regulations

Responsibility of Applicants for Promoting Objectivity in Research for which PHS Funding is Sought (42 C.F.R. Part 50, Subpart F)

Responsible Prospective Contractors (45 C.F.R. Part 94) (Note: this link opens a PDF document.)

NIH PowerPoint slides regarding the new regulations

FDA rules on Investigator Conflict of Interest: 21 CFR 54.4

 

National Science Foundation (NSF) Regulations

Award and Administration Guide Chapter IV, Part A. Conflict of Interest Policies

 

Department of Energy

Department of Energy Interim Conflict of Interest Policy Requirements for Financial Assistance

 

Organizational Conflicts of Interest

FAR 9.5

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