COI

Training and Disclosing for Individuals without a University of Arizona NetID

This information is for individuals without a University of Arizona NetID who have been asked to complete the University's Conflict of Interest training and disclosure requirements.

As stated in the University of Arizona's Conflicts of Interest & Commitment Policy (the "Policy"), the University is dedicated to maintaining high standards in the conduct of its research and research-related activities. In order to maintain a high level of objectivity, the conduct of research should be free from bias generated by a financial conflict of interest (FCOI) on the part of any investigator, regardless of title or position. Under the policy, 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."

Subrecipients, consultants, and certain collaborators who conduct research with or for the University under a federally funded award to the University must show adherence to federal conflict of interest regulations.  Additionally, investigators who conduct research involving human subjects must also comply with the University's conflict of interest training and disclosure requirements.

Any subrecipient or consultant that does NOT have its own federally-compliant policy and process within its organization that will be applied to their work on the federally funded award or IRB protocol can use the Office for Responsible Outside Interests as its conflict official and adhere to the University’s Policy and processes for a fee.  Subrecipients and consultants who will comply with the University’s Policy should review the conflict of interest fee schedule and the training material provided below to fulfill the conflict of interest training requirement.

The training materials provide information to enable investigators to properly disclose outside interests as required by certain federal and industry sponsors and the Policy. Additional resources can be found by using the links provided on the last page of the training material.

Training

1. Complete this form to request guest access to the UArizona training system (EDGE Learning). Make sure to select "Conflict of Interest Required Disclosure Training (Non-UA Investigators)”. (If you would like to request access for multiple individuals, please complete this form to request multiple/team access.)
2. You will receive an email with instruction on how to access the system and complete the training. Please allow 2 business days for account creation. If you don’t receive an email after the second business day, email Research-Training@arizona.edu.

Disclosing

If any of the three bullets below accurately describes your involvement with the University of Arizona, you must complete and submit the Disclosure Form for Subcontractors, Consultants, and Collaborators web form:

• You do not have a UA NetID and Password and are participating on a University of Arizona IRB project;
• You have received a subaward/subcontract from the University of Arizona that requires you to complete University of Arizona Conflict of Interest training and disclosure; or
• You are providing consulting services to the University of Arizona on a sponsor funded project that requires you to complete University of Arizona Conflict of interest training and disclosure.

Please contact the Office for Responsible Outside Interests at coi@email.arizona.edu or (520) 626-6406 with questions.

Conflict of Interest Responsibilities for Administrators

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 Conflicts of Interest & Commitment Policy to assist University of Arizona administrators in applying and complying with the University’s requirements regarding training, disclosure, review, and reporting of conflicts of interest.  Additionally, the Office for Responsible Outside Interests offer the Institutional Conflict of Interest Training for University Administrators.

What is an Institutional Conflict of Interest?

An Institutional Conflict of Interest, for purposes of this Policy, describes a situation in which Institutional Financial Interests may affect or appear to affect decisions made on behalf of the institution in connection with its Missions. Careful balancing and management of the University’s competing interests becomes necessary when Significant Financial Interests of the University or of a University Administrator have the potential to influence or appear to influence the conduct of research or business and administrative decisions made by or on behalf of the University.

An University Administrator is defined as:

Any University Employee in a position of administrative leadership of a college, academic department, business, or other administrative unit, where a regular job requirement is to make institutional decisions on behalf of the University of Arizona. The role of a University Administrator includes, but is not limited to, the following positions (whether such positions are staffed on an interim, full-time, or part-time basis):

• University Senior/Associate/Assistant Vice Presidents
• University Provost
• University Senior/Associate/Assistant Vice Provosts
• University Deans
• University Vice/Deputy/Associate/Assistant Deans
• University Directors
• University Department Heads/Chairs
• University Business Officers/Managers
• University Division Chiefs, Center Heads/Directors
• University Employees with the authority to sign agreements on behalf of the University of Arizona or Arizona Board of Regents
• University Employees whose duties and responsibilities include contracting or services related to Research administration, Research contracting, Research compliance, responsible conduct of Research, sponsored projects services, or technology transfer and who are in a position to influence decisions or commit University resources in the performance of the University Employee’s duties and responsibilities.
• Individuals who serve as Chairs on the University’s Institutional Review Board committees, regardless of whether such individuals are University Employees.

What do University Administrators have to disclose?

University Administrators must disclose Institutional Financial Interests within 30 days of acquiring a new Institutional Financial Interests or a change to an existing Institutional Financial Interests, and at least annually.  Institutional Financial Interests means:

1.  A University Administrator’s Significant Financial Interest;
2. A University Administrator’s Significant Personal Interest;
3. A loan of any amount between a non-publicly traded entity and a University Administrator or their family member;
4. The University’s equity or similar interest in a publicly traded entity valued at more than $100,000 or any amount in a non-publicly traded for-profit entity;
5. Substantial gifts, including in-kind gifts, received from an actual or potential commercial research sponsor or an individual or entity that owns or controls products being studied or tested as part of the Research;
6. Gifts totaling $1 million or more, cumulatively, and other gifts determined by the University’s Conflict of Interest Program to be substantial;
7. Any agreement with an external entity that includes the right for the University or a University Administrator or their family member to receive payments, royalties or other income from the commercial development or sale of an investigational product that is the subject of University Research;
8. Ownership by the Arizona Board of Regents (ABOR), on behalf of the University, of a patent and/or other intellectual property right in or sponsorship of an investigational new drug (IND) or device (IDE) application with respect to any drug or device for which human subject Research will be conducted;
9. Donation and sponsorship funds.

How to Disclose:

Prior to disclosing, please complete the Institutional Conflict of Interest Training for University Administrators.

For detailed instructions for completing your disclosure, please see Instructions for Submitting an Annual Disclosure Certification.

Please contact the Office for Responsible Outside Interests at coi@email.arizona.edu or (520) 626-6406 for assistance.

Click here to access the electronic COC Form: https://edisclosure.arizona.edu

University approval is required prior to Full Time University Employees (0.50 FTE or greater) entering into an Outside Commitment or Outside Employment. 

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 Conflict of Interest Program.

If in doubt as to whether approval is necessary, you are nonetheless encouraged to use the new Conflict of Commitment Form to apprise your department and college of the outside activity.

Approval Required University Employees with a 0.50 FTE or greater CANNOT start an Outside Activity until it has been approved.

Who needs to disclose their Outside Activity

All Investigators (regardless of their U of A FTE) and all University Employees with a 0.50 FTE or greater must submit a COC form in eDisclosure to disclose their Outside Activity.

Who needs to obtain approval

The COC form is to be used by all University Employees with a 0.50 FTE or greater to obtain approval prior to entering into any outside commitment or outside employment (Outside Activity), regardless of when that Outside Activity occurs.  This includes sabbatical leaves that involve an Outside Commitment (e.g., compensation or travel support provided by another institution).

If you do NOT engage in an Outside Activity, you do NOT need to submit a COC form.

If you engage in MULTIPLE Outside Activities, you will need to submit a COC form for EACH one.

NOTE Outside Activities at other postsecondary institutions create unique conflict concerns.  Please see Guidance for Consulting or Employment at Other Postsecondary Institutions for more information.

Publications and presentations based on performance of Outside Employment or an Outside Commitment should clearly identify the entity under which the performance occurred. Individuals may list their University affiliation, but each such publication or presentation should include a disclosure of funding and must not state or imply that project funding was provided by the University, nor that the individual’s contribution to such publication or presentation was part of their institutional responsibilities.

Timing

The COC form should be submitted for approval at least four (4) weeks prior to beginning the outside activity to allow a reasonable time for consideration of your request.

Approval of an outside activity lasts no more than one year and it is the submitter’s responsibility to seek renewal upon expiration.

What is an Outside Commitment?

Outside Commitments are activities that are related to your professional expertise and required a time commitment but are outside of your University duties and responsibilities.  Outside Commitment are for the benefit of an outside entity or individual but they are not covered by a fully executed written agreement between the University and the external entity or individual.

Why do I have to disclose my Outside Employment and Outside Commitments to the Office for Responsible Outside Interests?

The University requires that full-time (0.50 FTE or greater) employees disclose their Outside Activities for review of conflicts of commitment because the University has a fiduciary responsibility to ensure that inappropriate external influences outside the course and scope of one’s University employment do not affect the performance of one’s primary duties to the University. Outside Activities raise important questions related to time and energy allocation, University resource allocation, intellectual property protection and potential for conflicts of interest.

What is a Conflict of Commitment?

A Conflict of Commitment is a situation in which an individual accepts or incurs conflicting obligations between or among multiple employers or other entities.  A Conflict of Commitment occurs when a University Employee's Outside Activity interferes with, or could interfere with, their obligations to the University of Arizona.  Conflicts of Commitment relate to an individual's distribution of time and effort between their full-time duties as a University Employee or University research responsibilities and their responsibilities resulting from Outside Activities, University resource allocation, use of University assets, intellectual property protection and potential for conflicts of interest.

"Many organizational policies define conflicts of commitment as conflicting commitments of time and effort, including obligations to dedicate time in excess of organizational or research agency policies or commitments.  Other types of conflicting obligations, including obligations to improperly share information with, or to withhold information from, an employer or research agency,  can also threaten research security and integrity, and are an element of a broader concept of conflicts of commitment."

The University of Arizona’s Conflicts of Interest & Commitment Policy provides guidance to University employees and to the University in the identification of potential and actual conflicts of commitment.