The University of Arizona

Conflict of Interest Program

Report Misconduct

University Ethics and Compliance Hotline:


The University of Arizona encourages University faculty, staff, and students to engage in appropriate relationships with private industry and the nonprofit sector as part of its mission to disseminate knowledge through teaching, research, and public service. At times, however, these external activities may have the potential for a financial conflict of interest when the activities, income, or other interest affect, or appear to affect, the activities pursued within the University.

The Conflict of Interest Program (COIP) supports and promotes The University of Arizona's ethical conduct of research. In collaboration with the Institutional Review Committee and the Executive Review Committee, the Conflict of Interest Program works with The University of Arizona’s research community who are engaged in external relationships to ensure that all identified financial conflicts of interest or institutional conflicts of interest are appropriately managed, reduced, or eliminated.

Click Here for our training and disclosure system

Click Here on training and disclosure process for non-UA employees

What is a Conflict of Interest?

A Conflict of Interest in research are typically present when there is Signficant Financial Interest (SFI) or Significant Personal Interest (SPI) that can directly affect, or could appear to affect the professional judgement of a researcher when designing, conducting, or reporting research.

Who needs to disclose?

If you are a Research Investigator, Research Administrator or University Administrator then you must disclose your SFIs and/or SPIs and are defined by the University of Arizona's Individual Conflict of Interest in Research Policy:

An Investigator is defined 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."

A Research Administrator is defined as:

"Any individual employed by the University on a full-time or part-time basis whose responsibilities include participation in any manner in contracts or services related to research administration, research contracting, research compliance, responsible conduct of research, sponsored projects services, or technology transfer (whether at the University, college, department, or program level) and who are in a position to influence decisions or commit University resources in the performance of his/her Institutional Responsibilities."

A University Administrator is defined as:

"Any individual in a position of adminstrative leadership of the recognized University college, academic department, business, or other administrative unit, where a regular job requirement is to make institutional decisions on the behalf of the University of Arizona.  The role of a University Administrator includes, but is not limited to, the following positions (whether such positions are staffed on an interim, full-time or part-time basis):

University Vice/Associate/Assistant Presidents University Provost

University Vice/Associate/Assistant Provosts University Deans

University Vice/Associate/Assistant Deans University Directors

University Department Heads/Chairs University Business Officers/Managers

University Division Chiefs, Center Heads/Directors

University employees with the authority to sign agreements on behalf of the University of Arizona

Individuals who serve as Chairs on the University's Institutional Review Board committees, regardless of whether such individuals are employees of the University.

Where do I disclose?

      • If you have a UA NetId and Password:
      • If you 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

Why Disclose?

The University of Arizona is dedicated to ensuring the transparency and integrity of its research enterprise. Therefore, the University has implemented three policies that provide a framework against which the propriety and advisability of external activities can be measured. These policies and procedures for identifying, evaluating, and managing potential conflicts of interest are designed to meet applicable state law as well as federal regulations.

The individual policies are available on the University’s Research Policies website.The links below provide information on the policies and procedures associated with the disclosure and management of conflicts of commitment and interest at the University of Arizona.


Conflict of Interest Program | Research Gateway


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