Office for Responsible Outside Interests

When you enter into any commitment or obligation, even if it is not in writing, to Conduct Research for or on behalf of an individual or entity outside of UArizona (e.g., delivery of research results or data to the outside individual or entity) it constitutes an Outside Commitment and must be declared as such in advance of the activity, unless there is an existing signed agreement or contract between the outside individual or entity and the University of Arizona, on file with either RII Sponsored Project Services, RII Contracting Services or UAHS Research Administration, and which covers this specific commitment or obligation.

Non-sponsored research must be disclosed for conflict of interest review but is not an Outside Commitment that requires conflict of commitment approval unless you are Conducting the Research for or on behalf of an outside individual or entity.
 

An Investigator is any person who shares the responsibility of Conducting 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 person, regardless of title or position, who is responsible for Conducting Research performed by or under the auspices of the University.

This does not, however, include individuals whose performance is purely ancillary.  For example, office staff who provide ancillary support or hospital staff who provide intermittent care and do not make contributions to the research data are not Investigators.

Principal Investigators are responsible for identifying the Investigators who are participating in their research and the Office for Responsible Outside Interests will help Principal Investigators identify such individuals.  Principal Investigators should consider the following:

• The significance of the tasks assigned to the individual with regard to Conducting Research (i.e., making a significant contribution to the research results by participating in the design, development, testing, evaluation, conduct, reporting, review or oversight of the research, or in all of these activities);
• The degree of independence the individual may have in performing their assigned tasks;
• Whether the individual will be directly involved in the research intervention or consenting or evaluation of human research subjects; 
• Will the student/trainee be responsible for Conducting Research without direct oversight from an Investigator; and
• Whether the individual will be a collaborator or given authorship credit on a publication related to the Research or present Research findings at a meeting or conference.

For assistance in making this determination, you can review the following resources: Identifying Investigators & COI Disclosers and Who is an Investigator?, or contact OROI.

Conflict of interest (COI) and conflict of commitment (COC) reviews are separate because COI relates to bias in decisions and COC relates to a University employee's time & effort for UArizona, UArizona resources and UArizona Assets.

Sponsors & funders have identified the following concerns: 

1.    conflicts of interest
2.    shadow labs
3.    loss of Intellectual Property
4.    conflicts of commitment, including theft of time, resources and assets
 

Yes, since UArizona receives federal funding, all University Employees are expected to follow federal regulations as embodied in the Conflicts of Interest & Commitment Policy.

As a public University and recipient of federal research funding, UArizona is required to comply with federal regulations, state law and ABOR policies.  Additionally, UArizona has a fiduciary responsibility to ensure inappropriate external influences do not affect the performance of one’s primary duties to UArizona.

The information collected in eDisclosure allows UArizona to ensure development and implementation of management strategies in order to facilitate our faculty’s continued cutting-edge research and that all University Employees meet regulatory requirements.

More information on disclosure requirements can be found on our History of Disclosure Requirements webpage.

UArizona’s policy can be found here: Conflicts of Interest & Commitment Policy