Office for Responsible Outside Interests

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.
 

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 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.
 

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.