University of Arizona Policy
The University of Arizona has a responsibility to ensure integrity and transparency in managing the intersections of its public and private interests, thereby preserving the integrity of its research enterprise and the public’s trust. The University has implemented its Individual Conflict of Interest in Research Policy to assist University of Arizona investigators in applying and complying with the University’s requirements regarding training, disclosure, review, and reporting of conflicts of interest.
The Individual Conflict of Interest in Research Policy is part of an institutional culture of ethics and good judgment in the University’s performance of all of its missions (teaching, research, public service) and its administrative and business operations. Each investigator has an obligation to become familiar with, and abide by, this policy. Research, Discovery & Innovation is responsible for ensuring compliance with this policy.
When in doubt, disclose!
For an overview of the distinctions between the Individual Conflict of Interest in Research and the Conflict of Commitment Policies, please see this COMPARISON TABLE.
How to Disclose
Prior to disclosing, you must complete a short Conflict of Interest training. This training is embedded in the Online Disclosure. Log in to the disclosure system using your NetID and Password to complete the required training and your disclosure. The training is valid for four (4) years, after which time you must complete the training again. It is recommended that you keep a copy of your training of your training certificate.
For detailed instructions for completing your disclosure, please see Instructions for Completing Your Financial Disclosure.
Who is required to complete a disclosure?
All investigators are required to complete a disclosure. An investigator is defined as any person who is responsible for the design, conduct, or reporting of research, regardless of title or position. This includes, but is not limited to, the principal investigator ("PI"), co-PI, co-investigator, project director ("PD"), Co-PD, and senior or other key personnel. Students, trainees, postdoctoral researchers, collaborators, volunteers, consultants, or other staff members might also be investigators if those individuals have some degree of independence in performing some aspect of the design, conduct, or reporting of research.
What do I need to disclose?
An investigator is required to disclose all significant financial interests (as defined below) or significant personal interests (as defined below) that he or she holds or that his or her spouse, dependent children, or domestic partner holds if those outside interests would (i) reasonably appear to be related to his or her institutional responsibilities or (ii) would reasonably appear to be affected by the research. Institutional responsibilities include an investigator's professional responsibilities on behalf of the institution receiving the funds, including, but not limited to, research, research consultation, teaching, professional practice, institutional committee memberships, and service on panels such as Institutional Review Boards or Data and Safety Monitoring Boards.
- Significant Personal Interests: A significant personal interest is defined as any managerial, professional, or fiduciary position held in any third-party organization (e.g., as an officer, director, trustee, advisory board member, board of directors, or other managerial position), whether or not the investigator (or the investigator's spouse, dependent children, or domestic partner, as applicable) is compensated for that position.
- Significant Financial Interests: A significant financial interest is a financial interest consisting of one or more of the following interests of the investigator (and those of the investigator's spouse, dependent children, or domestic partner) that reasonably appears to be related to the investigator's institutional responsibilities:
- Intellectual Property: Intellectual property rights and interests (e.g., patents, copyrights), upon receipt of income related to such rights and interests.
- Public Entities: Remuneration received from a publicly-traded entity during the twelve months prior to disclosure that (in combination with the value of any equity interest in the entity) exceeds $5,000. Remuneration includes salary and any payment for services not otherwise identified as salary (e.g., consulting fees, honoraria, paid authorship); equity interest includes any stock, stock option, or other ownership interest, as determined through reference to public prices or other reasonable measures of fair market value.
- Non-Public Entities: Remuneration received from a non-publicly traded entity during the twelve months prior to disclosure that exceeds $5,000 when aggregated or any equity interest held in a non-publicly traded entity.
- PHS-funded investigators: Investigators who are working on a PHS-funded research project also must disclose the occurrence of any reimbursed or sponsored travel related to their institutional responsibilities. Investigators do not have to report travel that is reimbursed or sponsored by a federal, state, or local government agency, an institution of higher education, an academic teaching hospital, a medical center, or a research institute that is affiliated with an institution of higher education.
Please see the Policy for more detailed information, including what is not required to be disclosed. Some common examples of outside interests that do not need to be disclosed include income from investment vehicles such as mutual funds and retirement accounts, as long as the investigator does not directly control the investment decisions made by the investment managers within these funds or accounts.
What if I have nothing to report?
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 interests to report on the form and submit the form.
How often do I need to update my disclosure?
- Initially: The disclosure form should be submitted prior to the submission of a proposal and prior to participating in any research activities at the University.
- 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 even if the investigator has nothing new to report.
What happens after I submit my disclosure?
The Conflict of Interest Program will conduct an initial review of the disclosure. If the investigator has nothing to disclose, then no further action is required on the part of the investigator at that time. The investigator will be required to recertify his or her disclosure annually and within 30 days of acquiring a new significant financial interest or significant personal interest.
If the investigator discloses a significant financial interest or significant personal interest, then the Conflict of Interest Program and, if applicable, the University's Institutional Review Committee ("IRC") will review the disclosure to determine if the disclosed outside interests could directly and significantly affect the design, conduct, or reporting of research or could compromise, or appear to compromise, the investigator's objectivity in the performance of his or her institutional responsibilities ("financial conflict of interest"). The IRC is a University-wide committee consisting of at least ten faculty members. If the IRC finds a financial conflict of interest exists, the Conflict of Interest Program will work with the investigator to manage, reduce, or eliminate the financial conflict of interest. The investigator must comply with all terms and conditions of a management plan or any administrative directives issued by the IRC.
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 & contracting 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. This term does not include (a) individuals whose responsibilities are purely clerical or are performed solely under immediate supervision; (b) employees of Purchasing and Contracting Services (who are subject to Procurement and Contracting Services policy number 1.4); or (c) senior-level “University Administrators” (who are subject to the Institutional Conflict of Interest policy).”
What to Disclose
Research Administrators have the responsibility to disclose all outside interests, including those of their family members and relatives, which can reasonably be seen as related to their institutional responsibilities.
When to Disclose
- Research administrators must submit a disclosure to their supervisor upon becoming award of an outside interest that is related to, or that may reasonably appear to be related to, their institutional responsibilities.
- Disclosures should be updated annually, or more often in the event of a change in the outside interests.
How to Disclose
To disclose, Research Administrators must complete the Research Administrators Disclosure form and submit it to their supervisor for review and signature.
For assistance, please contact the Conflict of Interest Program at firstname.lastname@example.org or (520) 626-8266.