Procedures Related to Conflict of Interest
An Investigator is defined by the University of Arizona’s Individual Conflict of Interest in Research Policy as:
"any person who is responsible for the design, conduct, or reporting of 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 persons involved in the Conduct of Research, regardless of title or position, who are responsible for the design, conduct, or reporting of Research performed by or under the auspices of the University. This may include students, trainees, collaborators, volunteers, and Consultants if those individuals have some degree of independence in performing some aspect of design, conduct, or reporting of the Research."
Where to go for training if you have a UA NetID and Password:
- Training for University employees is provided through the University's online disclosure and training system. To access the system, log into the UA Disclosure of Significant Financial Interest site using your UA NetID and password. If you have already completed your training, your disclosure will reflect the date you last completed training.
- See Individual Conflict of Interest for links to instructions for using the disclosure and training system.
Where to go for training if you do NOT have a UA NetID and Password:
- University of Arizona training for non-University employees, including subrecipients, contractors, and consultants, is available here.
When training must be updated:
- Investigators must update training every four (4) years after initial training is completed.
- All Investigators may be asked to update training earlier than four (4) years in the event that the University revises training in a significant enough manner as to require campus-wide re-training.
- Individual Investigators may be asked to updated training earlier than four (4) years in the event that the Investigator is found to be noncompliant with the University’s Individual Conflict of Interest in Research Policy.
Where to disclose if you have a UA NetId and Password:
- Disclosures for individuals with UA NetIDs and Password are completed using the online UA Disclosure of Significant Financial Interest system.
- Instructions for completing the disclosure are provided here.
Where to disclose if you have do NOT have a UA NetId and Password:
- Complete the Disclosure Form for Subcontractors, Consultants, and Collaborators if any of the following describes your involvement with the University of Arizona:
- You do not have a UA NetID and Password and are participating on a University of Arizona IRB project
- You have received a subaward/subcontract from the University of Arizona that requires you to complete University of Arizona Conflict of Interest training and disclosure, and/or
- You are providing consulting services to the University of Arizona on a sponsor-funded project that requires that you complete University of Arizona Conflict of interest training and disclosure.
When must Disclosures be submitted:
- All Investigators who will participate in research activities, either funded or non-funded, and including any human subjects research, at the University must complete a disclosure prior to participating in any research activities.
- All Investigators participating in federally funded research activities, including sub-federal awards, must complete an initial disclosure prior to the submission of any federal or sub-federal proposal, even if they have yet to participate in research activities.
When must Disclosures be updated:
- For Initial Disclosures where the Investigator has no Significant Financial Interests disclosed, the disclosure must be updated:
- Annually, between June 1 and June 30 of each calendar year;
- Within thirty (30) days of acquiring a new significant financial interest or a change in an existing significant financial interest.
- For Initial Disclosures where the Investigator has disclosed one or more Significant Financial Interests, subsequent Disclosures must be made upon the following schedule:
- Prior to proposal submission for each new federally funded research project where the investigator is named in the proposal;
- Prior to the expenditure of funds on any funded research project on which the investigator is participating; and
- Prior to submission of Institutional Review Board application for any research involving human subjects