What is Significant Use of University Resources?

“Significant Use of University Resources” includes but is not limited to: use of research funding; use of funding allocated for asynchronous or distance learning programs; use of telecommunication and data services beyond ordinary use; use of university computing resources; use of instructional design or media production services; access to and use of research equipment and facilities or production facilities; use of University Assets* such as paid employee time, proprietary information, intellectual property (such as patents, trademarks, and copyrights), logos, land and buildings.

The use of library resources, personal workstations, or personal computers are not typically construed as Significant Use of Board or University Resources.

 

*University Assets is fully defined in the University's Misuse of Assets Policy.

"If created/authored/wrote, music/media/video/book/article that wanted to be used by an outside agency and was willing to pay me but required no actual time commitment from me, do I need to go through the COC process? "

This depends on your UA role (whether an Employee, Administrator and/or Investigator – An complete overview of UA roles and Disclosure requirements can be found here)  

  • If you are an Investigator, receiving remuneration/income in any amount from Intellectual Property rights, such as patents or copyrights will make this a Significant Financial Interest that needs to be disclosed via eDisclosure. Additionally,
  • If you are a UA employee whose FTE is 0.5 or greater, the definition of Outside Employment and Outside Commitment is included below for your review. The Outside Commitment Decision Tree may be of assistance when making the determination as to whether an activity requires disclosure. Additionally, the Disclosure Table resources provide an overview of the disclosure requirements.  

Outside Employment refers to any employment relationship outside of the University requiring a time commitment.

Outside Commitments: (1) are professional and other activities that are related to a University Employee’s professional expertise, outside of their University duties and responsibilities; (2) are for the benefit of an external entity or individual and are not covered by a fully executed written agreement between the University and the external entity; and (3) require a time commitment. Outside Commitments include Outside Employment, independent contracts for consulting services, private consulting groups comprised of University Employees, volunteer/pro bono work, appointments at postsecondary educational institutions, and foreign components, as that term may be updated by the University’s Office for Responsible Outside Interests.

Also, please refer to the University’s TLA-100 The Intellectual Property Policy in case applicable.

"I will only need to submit a COI when I am notified that the proposal will get funded, not while we are still waiting for a decision, correct?"

An up-to-date COI disclosure (either an Annual Disclosure or Research Certification submitted within the last 364 days) is required at the time of proposal to a federal funding agency.

Additionally, Federal regulations prohibit expenditures on Awards until after the COI review process is complete. Our office desires to see all funded research go forward without delay.

Therefore, to avoid Award Holds, you are asked to submit Research Certifications early. Generally, Research Certifications are available in eDisclosure 60 days prior to the project start date listed in the Institutional Proposal. (For certain clinical trials, it may be fewer than 60 days) eDisclosure will send a notification to the Investigator as part of the UAccess Research/Sponsored Projects integration. If at any time you have been informed that any given project was not funded  you would then advise sponsor@arizona.edu as soon as possible that the specific project will not be funded and no action is required for the Research Certification.
 

Why do personnel on my IRB protocol have to submit a Research Certification?

The Human Subjects Protection Program requires protocol personnel submit a Research Certification via eDisclosure for each project they are listed on in eIRB.  For sponsored research, the Human Subjects Protection program has mapped IRB protocol roles to the sponsored project personnel categories. This mapping tool can be used to ensure protocol personnel complete Research Certifications: Investigator Mapping.

"I am a graduate student who will be working as a teaching assistant this fall. I am doing my PhD and I will be teaching at the Department. What Conflict of Interest training do I have to complete – or does this apply to research assistants only?"

If you will be participating in research under the auspices of the University, you are required to complete the Required COI Disclosure Training through Edge Learning and submit a disclosure via via eDisclosure. These requirements apply to anyone who is an “Investigator” on a research project at the University (whether or not externally funded).  “Investigator” is a defined term in the Conflicts of Interest and Commitment policy, and generally means “any person who shares the responsibility for the design, conduct, or reporting of Research” and may include students, postdocs and trainees.

More details can be found on the Conflict of Interest Requirements for Students, Postdocs and Trainees webpage.

"Given that so many colleges and academics were taken by surprise by this policy, I strongly recommend that the policy be reviewed by the full Faculty Senate for deliberation, for comparison with peer universities, and for revision."

RII also believes that it was important to get feedback from Faculty Senate and other stakeholders.  As such, the policy underwent multiple stakeholder reviews, including review by Faculty Senate and APPC.  It was presented to the full Faculty Senate at its December 2, 2019, senate meeting and circulated to the Faculty Senate for review prior to implementation on an interim basis in May 2021.  It was also discussed at a January 9, 2020 APPC meeting in which Taren Ellis Langford was present.  (Please know that all suggestions and edits from APPC were incorporated into the final policy.)

Here is the full list of stakeholders who were provided a copy of the draft policy and invited to participate in the review, feedback and comment period:

  • Faculty Senate
  • Associates Deans for Research
  • Student Affairs Policy Committee Academic Personnel Policy Committee (APPC)
  • Associated Students of the University of Arizona (ASUA)
  • Research Policy Committee (RPC)
  • Institutional Review Committee (IRC)
  • Dean's Council
  • Procurement & Contracting Services (PACS)
  • Internal Audit
  • Tech Launch Arizona
  • Classified Staff Council
  • Appointed Professionals Advisory Council (APAC)
  • Graduate & Professional Student Council
  • Executive Review Committee (ERC)
  • Public Comments
 

 

"I have been invited by a school district to provide professional development and will be paid for 6 hours of work. Is this a COC or COI?"

Please work with your college to determine if this is outside of your institutional duties and responsibilities.  If this activity meets the definition of an Outside Commitment, it should be disclosed for conflict of commitment review.  The Outside Commitment Decision Tree on our Disclosure Requirements webpage may be of assistance in making this determination.

 

If you are an Investigator, receipt of remuneration (includes stipends and honorariums) in the amount of $5,000 or more will make this a Significant Financial Interest that needs to be disclosed.

 

If you are an Investigator and receive remuneration (includes stipends and honorariums) of any amount from a foreign entity, this must be disclosed as a Foreign Interest for conflict of interest review.

"If a local teacher or school asks me to assist with a curriculum or teaching project (per my expertise), is this a COC? It seems like it would be a service project. How does one distinguish between service and a COC?"

Please work with your college to determine if this is outside of your institutional duties and responsibilities.  If this activity meets the definition of an Outside Commitment, it should be disclosed for conflict of commitment review.  The Outside Commitment Decision Tree on our Disclosure Requirements webpage may be of assistance in making this determination.

 

If you are an Investigator, receipt of remuneration (includes stipends and honorariums) in the amount of $5,000 or more will make this a Significant Financial Interest that needs to be disclosed.

"I’ve agreed to be on an advisory board for the Oxford Dictionary of African American English. I’ll be given more than $5000 and this is my area of expertise. What do I need to do for COI or COC?"

If this activity meets the definition of an Outside Commitment, it should be disclosed for conflict of commitment review.  The Outside Commitment Decision Tree on our Disclosure Requirements webpage may be of assistance in making this determination.

 

If you are an Investigator, receipt of remuneration (includes stipends and honorariums) in the amount of $5,000 or more will make this a Significant Financial Interest that needs to be disclosed.

 

Disclosures must be submitted in eDisclosure.  If you experience any issues in eDisclosure, please contact OROI at coi@arizona.edu.

"I have been invited to participate in a small conference. The conference is funded by a grant and the grantee is reimbursing participants for travel expenses. Is this a COC/COI?"

There is not enough information to determine whether this should be disclosed for conflict of interest review.  (e.g., Is it a UArizona grant?  Are you funded by a PHS agency or the Dept of Energy?)  Please contact OROI at coi@arizona.edu or visit our office hours (1st & 3rd Thursday, 2 pm – 3 pm; Connect via Zoom) for assistance.

 

If this activity meets the definition of an Outside Commitment, it should be disclosed for conflict of commitment review.  The Outside Commitment Decision Tree on our Disclosure Requirements webpage may be of assistance in making this determination.