Investigators and Collaborators
The Objectivity in Research (OIR) policy requires the completion of Financial Conflict of Interest (FCOI) training and submission of a Financial Interest Disclosure (FID) form by those who meet the definition of a covered individual and are involved in University research.
If the research does not involve human subjects research, a Covered Individual (CI) is an individual who is responsible for the design, conduct or reporting of research. If the research involves human subjects, the definition is broader and Covered Individuals are individuals that are involved in the design, conduct, or reporting of research.
Principal Investigators (PI), co-Investigators, faculty sponsors, mentors, and research assistants are examples of roles/positions/titles who often meet the definition of a covered individual.
The PI of the research should determine which research team member meets the definition of a CI.
Once CIs are identified, the next step is to determine the appropriate training and disclosure process.
To ensure timely processing of protocols, proposals and/or awards, all CIs should address the appropriate requirements well in advance of any submissions to the IRB, OSP, or OIE.
Requirements for University Faculty, Staff, or Students (UT CI)
UT CIs must complete the University FCOI training and submit a FID form. The FID form instructions and web link are provided via e-mail one business day after the FCOI training is complete.
Requirements for Non-UT Covered Individuals (Non-UT CI)
One of the requirements below will apply:
Requirement A: The non-UT CI is conducting research on behalf of their affiliated institution, the institution has established a policy that conforms to Public Health Service (PHS) regulations, and the non-UT CI is compliant with the institution’s policy.
The authorized representative of the non-UT CI’s home institution must send via e-mail or letterhead confirmation of:
- The establishment of a PHS compliant FCOI policy; and
- The non-UT CI’s compliance with their respective policy.
Complete and send the below statement to email@example.com (copying the IRB Program Coordinator and OSP staff, as applicable). Please also include a copy of or a link to the institution’s FCOI policy.
“[NAME OF INSTITUTION] certifies that we have a compliant financial conflict of interest policy that conforms to the requirements of 45 CFR Part 94 and 42 CFR Part 50, Subpart F. We certify that [NAME OF COOPERATING RESEARCHER (e.g. John Smith, Ph.D)] has complied with our policy. Prior to expenditure of funds and within 45 days of any subsequently identified FCOI, we will report to The University of Texas at Austin any identified financial conflict of interest related to the award, and provide an indication whether the conflict has been eliminated, reduced, or managed.”
Requirement B: The non-UT CI is engaged in University research as an independent researcher/consultant or is affiliated with an institution/entity that does not have an FCOI policy that conforms to PHS regulations.
The non-UT CI must follow the below steps in the order described.
- Obtain a guest UT EID. Ensure an active and current e-mail address is listed in your EID profile.
- Complete the University of Texas at Austin FCOI training module. Select to view training slideshow OR download training PDF.
- Certify completion of the training as instructed on the last slide of the FCOI training module to receive credit.
- Submit a FID form. The FID form instructions and web link are provided via e-mail one business day after The Office of Research Support manually updates your FCOI training record.
The Office of Research Support will manually update your training record after you certify completion of your training. This is required prior to your submission of the FID form. All efforts to send your certification during business hours (Monday-Friday 8:00 a.m. to 4:30 p.m. CST) are appreciated.
Contact The Office of Research Support with questions, comments, or concerns regarding COI at firstname.lastname@example.org or (512) 232-2044.