The University of Arizona


Under the University of Arizona’s Institutional Conflict of Interest Policy, sponsorship of an Investigational New Drug (“IND”) or an Investigational Device Exemption ("IDE") application by UA or UA personnel may create an Institutional Conflict of Interest. Accordingly, if you are applying for an Investigational New Drug (IND) or an Investigational Device Exemption (IDE) then you must get approval from the Executive Review Committee.  Please submit an IND/IDE COI Worksheet to the COI Program as far in advance of your anticipated IND/IDE submission date as possible, to minimize the risk of delays while awaiting ERC review.


If an investigator is no longer involved in an IRB protocol then the PI must contact the IRB office to update the list of personnel on the project.  Once the list is updated by the PI, it will take a few days for the names to update in the system so a few more reminder emails may still get sent while the update is happening.

The proposals that are populated in your disclosure are pulled from UAccess Research.  If a proposal was not funded and it is showing up in your disclosure it is most likely because Sponsored Projects was not notified that the proposal was not funded. Please use the “Set as not required” option in your disclosure and select the appropriate reason from the drop down menu.  Also, you or your business office should contact Sponsored Projects & Contracting Services to notify them that the proposal was not funded.  They will set the proposal to the appropriate status.

UAccess Analytics houses the Conflict of Interest Dashboard.  You can use this site to review who has completed the conflict of interest training and disclosure requirements and to see if there are outstanding requirements that an individual needs to complete.


You still need to complete the required training and disclosure requirements even if you have no outside interests that meet the definition of a significant financial interest or a significant personal interest as described above. In this case, you will simply certify that you have no outside interests to report on the form and submit the form.  

 For University employees or affiliates with system access, instructions for completing the online disclosure and training form are available on the Disclosure Instructions page. You will find helpful hints, guides and step-by-step instructions.


For University employees or affiliates with system access, log into the Online Disclosure and Training system with your Net ID and password.

For non-University employees, or individuals without system access, a web form is provided for your completion.


  • Within 30 days of Acquiring a New Interest: New significant financial interests and significant personal interests should be disclosed to the Conflict of Interest Program within 30 days of acquiring a new interest by completing a new disclosure form.
  • Annually: Disclosure forms are required to be re-certified annually between June 1st and June 30th of every year even if the investigator has nothing new to report.
  • If you have one or more significant financial interests or significant personal interests, you must update your disclosure when any of the following occur:
    • Your financial interest changes (i.e., the value of your interest increases or decreases, your role in the entity changes, or if you no longer hold an interest in the entity).
    • Each time you have a new proposal or award, a new IRB research project, or non-sponsored research project.

For more information on disclosures, review the Disclosure Instructions page.

All investigators must complete conflict of interest training as follows:

  1. Prior to participating in research activities at the University;
  2. At least every four years thereafter for the life of the project;
  3. Any time after the University revises the Individual Conflict of Interest in Research Policy or the corresponding procedures in any manner that affects the requirements of the investigators; and
  4. Any time after the University finds that an investigator is not in compliance with the Individual Conflict of Interest in Research Policy or a management plan.

Investigators must complete:

  • Conflict of Interest Training; and
  • A Conflict of Interest Disclosure Form

An investigator is any person who is responsible for the design, conduct, or reporting of research, regardless of his or her title or position at the University.

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 individuals 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 the design, conduct, or reporting of the research.

The term "investigator" does not include individuals whose performance within the research is purely ancillary or occurs solely under immediate supervision.