Office for Responsible Outside Interests

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.

When is Research an Outside Commitment?

When you enter into any commitment or obligation, even if it is not in writing, to Conduct Research for or on behalf of an individual or entity outside of UArizona (e.g., delivery of research results or data to the outside individual or entity) it constitutes an Outside Commitment and must be declared as such in advance of the activity, unless there is an existing signed agreement or contract between the outside individual or entity and the University of Arizona, on file with either RII Sponsored Project Services, RII Contracting Services or UAHS Research Administration, and which covers this specific commitment or obligation.

Non-sponsored research must be disclosed for conflict of interest review but is not an Outside Commitment that requires conflict of commitment approval unless you are Conducting the Research for or on behalf of an outside individual or entity.

Who is an Investigator?

An Investigator is any person who shares the responsibility of Conducting Research.  

This includes, but is not limited to, the Principal Investigator (PI), Co-PI, Co-Investigator, Project Director (PD), Co-PD, Senior/Key Personnel, and any other person, regardless of title or position, who is responsible for Conducting Research performed by or under the auspices of the University.

This does not, however, include individuals whose performance is purely ancillary.  For example, office staff who provide ancillary support or hospital staff who provide intermittent care and do not make contributions to the research data are not Investigators.


Principal Investigators are responsible for identifying the Investigators who are participating in their research and the Office for Responsible Outside Interests will help Principal Investigators identify such individuals.  Principal Investigators should consider the following:

  • The significance of the tasks assigned to the individual with regard to Conducting Research (i.e., making a significant contribution to the research results by participating in the design, development, testing, evaluation, conduct, reporting, review or oversight of the research, or in all of these activities);
  • The degree of independence the individual may have in performing their assigned tasks;
  • Whether the individual will be directly involved in the research intervention or consenting or evaluation of human research subjects; 
  • Will the student/trainee be responsible for Conducting Research without direct oversight from an Investigator; and
  • Whether the individual will be a collaborator or given authorship credit on a publication related to the Research or present Research findings at a meeting or conference.


For assistance in making this determination, you can review the following resources: Identifying Investigators & COI Disclosers and Who is an Investigator?, or contact OROI.

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 or at 520-626-6406. For questions about Substantial Interests, contact Ted Nasser at or at 520-621-5449.

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 or at (520) 626-8266.

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