Office for Responsible Outside Interests

COI:  Income received from the University of Arizona is exempt from the COI disclosure requirements

COC:  Please work with your college/unit leadership to determine if they consider this to be an Outside Commitment.  Pursuant to policy, 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.  Here, the teaching commitment is not for the benefit of an external entity or individual. With that said, an individual’s supervisor/department/college could require submission of a COC form for review and approval to ensure the individual’s institutional duties and responsibilities are properly covered if they desired to do so.

Outside Commitments require prior approval.  In an ideal world, the COC form would be submitted in eDisclosure 4 weeks prior to the start date to ensure college and department reviewers have an opportunity to review the form, resolve concerns and/or implement a management plan.  Realizing that submission 4 weeks prior to the start date is not always possible, we ask that individuals email us to flag a fast-approaching start date so that we can work with the approvers to ensure all questions are answered, etc. 

If the Outside Commitment is not approved, the individual cannot engage in the Outside Commitment.

OROI is available to work with college/department approvers to discuss concerns and develop a COC management plan.  More details about the COC review process are available on our COC & COI Review Processes webpage. 

Outside Commitments require prior approval.

Both.  Outside Commitments must be disclosed in eDisclosure, at which time OROI will initiate the review process.  

More details about the COC review process are available on our COC & COI Review Processes webpage. 

Research and Research Project mean any organized program of scientific inquiry that involves a systematic investigation, study, or experiment designed to develop or contribute to generalizable knowledge that is performed at or under the auspices of the University. Research includes non-sponsored research, research fellowship and training programs, and research-related activities in undergraduate, graduate, and postdoctoral education.  It also includes some educational activities that are supported by a research sponsor.

Federal funding agencies indicate that Research can be thought of as:

1. "a process to discover new knowledge,"
2. "a scientific study of nature that sometimes includes processes involved in health and disease," and/or
3. "creative and systematic work undertaken in order to increase the stock of knowledge—including knowledge of humankind, culture and society—and to devise new applications of available knowledge."

Federal funding agencies further indicate that one can consider whether the project includes:

• "a systematic, intensive study directed toward greater knowledge or understanding of the subject being studied, or
• a systematic study directed specifically toward applying new knowledge to meet a recognized need, or
• a systematic application of knowledge to produce useful materials, devices, and systems or methods, or
• development [which] may include designing, developing, and improving prototypes and processes to meet specific requirements."

See:  HHS, NCI, NSF

A foreign entity is:

1. A public or private organization located in a country other than the United States and its territories that is subject to the laws of the country in which it is located, irrespective of the citizenship of project staff or place of performance; or
2. A private nongovernmental organization located in a country other than the United States that solicits and receives cash contributions from the general public; or
3. A charitable organization located in a country other than the United States that is nonprofit and tax exempt under the laws of its country of domicile and operation, and is not a university, college, accredited degree granting institution of education, private foundation, hospital, organization engaged exclusively in research or scientific activities, church, synagogue, mosque or other similar entities organized primarily for religious purposes; or
4. An organization located in a country other than the United States not recognized as a Foreign Public Entity.  A Foreign Public Entity is (1) A foreign government or foreign governmental entity; (2) A public international organization, which is an organization entitled to enjoy privileges, exemptions, and immunities as an international organization under the International Organizations Immunities Act (22 U.S.C. 288f); (3) An entity owned (in whole or in part) or controlled by a foreign government; or (4) Any other entity consisting wholly or partially of one or more foreign governments or foreign governmental entities.

Investigators must:

1.    Complete the Required COI Disclosure Training after July 1, 2021.
2.    Complete the Required COI Disclosure Training once every 4 years thereafter.
Note:  OROI may direct an Investigator to complete the training more frequently.
3.    Submit an annual certification.  This can be an Annual Disclosure Certification or Research Certification.
4.    Update their certification within 30 days of a change to an existing Outside Interest.
5.    Update their certification within 30 days of acquiring a new Outside Interest.
6.    Submit a Research Certification for all non-sponsored and sponsored Research.
 

At the time of proposal submission to a federal funding agency, Investigators must have an up-to-date COI certification.  That means each Investigator has:

1.    Submitted either an Annual Disclosure Certification or a Research Certification in the last 364 days, and
2.    Does not have any changes to an existing Outside Interest or new Outside Interest.
 

In the past, University Employees were asked to disclose Outside Commitments in the COC database and Outside Interests in the COI database.

The Conflicts of Interest & Commitment Policy incorporated and replaced the following policies:

1.    Conflict of Commitment Policy
2.    Conflict of Interest (UHAP) Policy
3.    Conflict of Interest in Purchasing Policy
4.    Individual Conflict of Interest in Research Policy
5.    Institutional Conflict of Interest Policy

Now, eDisclosure serves as a single platform to meet all policy disclosure requirements.