Last updated March 5, 2014
A. Conflict of Interest FAQs
1. Is the "Promoting Objectivity in Research by Managing, Reducing or Eliminating Financial Conflicts of Interest" policy the same or different than "Conflict of Interest, Conflict of Commitment, and Outside Activities?" policy?
The “Conflict of Interest, Conflict of Commitment, and Outside Activities” policy (UTS 180) is different than the “Promoting Objectivity in Research by Managing, Reducing or Eliminating Financial Conflicts of Interest” policy that is described in this FAQ section and throughout The Office of Research Support website.
The “Promoting Objectivity in Research by Managing, Reducing or Eliminating Financial Conflicts of Interest” policy is effective as of August 23, 2012 and requires researchers to complete FCOI training and submit a FID form.
2. If I completed FCOI training and submitted a FID form as required by the “Promoting Objectivity in Research by Managing, Reducing or Eliminating Financial Conflicts of Interest” (UTS 175/HOP 7-1210) policy, do I need to comply with the disclosure requirements of the “Conflicts of Interest, Conflicts of Commitment, and Outside Activities” (UTS 180/HOP 5-2011) policy?
You may not need to re-disclose information under UTS 180/HOP 5-2011 policy if you disclosed it under UTS 175/HOP 7-1210. However, you should review the policy for UTS 180/HOP 5-2011 and contact the Office of the Provost to confirm.
3. What is a “Financial Conflict of Interest?”
A “Financial Conflict of Interest” is a financial interest which a) has been determined by the Conflict of Interest Official as having potential for directly and significantly affecting the design, conduct, or reporting of the research or is in an entity whose financial interest appears to be affected by that research, and b) is subject to the University’s development of a management plan to avoid any direct and significant impact to the covered individual’s research.
4. Who is a “Covered Individual?”
A “Covered Individual” is an individual who, regardless of title or position, is responsible for the design, conduct, reporting, review, or oversight of research, including, but not limited to a principal investigator, co-investigator, or project director, and who must file and update financial disclosure statements under the University policy.
This definition also applies to any student enrolled at the University who is responsible for the design, conduct, or reporting of research.
5. Do postdoctoral fellow and graduate students need to disclose?
If the postdoctoral fellow or graduate student meets the definition of a Covered Individual, then they must submit a disclosure.
6. Who is a “Covered Family Member?”
A “Covered Family Member” includes:
- a spouse;
- a dependent child or stepchild or other dependent, for purposes of determining federal income tax liability during the period covered by the disclosure statement;
- and a related or non-related, unmarried adult who resides in the same household as the covered individual and with whom the covered individual is financially interdependent as evidenced, for example, by the maintenance of a joint bank account, mortgage, or investments.
If the covered individual is in doubt about whether an individual is a covered family member, the covered individual should resolve the doubt in favor of disclosure.
7. What does “Institutional Responsibilities” mean?
“Institutional responsibilities” are any of the professional responsibilities of a covered individual performed on behalf of the University, including consultation, teaching, professional practice, research, University committee membership, or service on a University panel such as an Institutional Review Board (IRB) or Data and Safety Monitoring Board (DSMB).
8. Do I have to complete the COI training and submit a disclosure form if I do not have any financial interests to report?
Yes. If you are responsible for the design, conduct, or reporting of research you must complete the training and submit a disclosure form. Your responses to the disclosure form will document that you do not have any financial interests. After your disclosure form is accepted, you will still be required to update your disclosure form annually or when changes occur (within 30 days of the change)
9. Is completion of the COI training and submission of the disclosure form only required by researchers who have financial conflicts of interest (FCOI)?
No. The COI training and disclosure form are required of all Covered Individuals, regardless of whether or not the Covered Individual holds any financial interests.
Keep in mind that all disclosures will be reviewed and a determination made as to whether the disclosure is likely to represent an FCOI. Not all financial interest disclosures will result in such a conflict of interest determination. If a financial interest appears to be, or could be perceived as, an FCOI, it will be forwarded to the Objectivity in Research Committee for further review and, if applicable, development of a management plan. This will all be accomplished with the researcher(s) and others (Dean, Department Chair, etc.) involved, if applicable, to assure an accurate and fair determination.
10. The Federal regulations require COI training and financial interest disclosures from PHS-funded researchers. I do not receive PHS funding. Does this mean I do not have to complete the training or submit the disclosure form?
No. The University policy for Promoting Objectivity in Research by Managing, Reducing, or Eliminating Conflicts of Interest is more stringent than the Federal regulations. The University policy applies broadly to research performed at, or on behalf of the University, without regard to whether the research has external funding, and if externally funded, regardless of the funding source.
11. I need to apply for PHS-funding immediately. Can I submit a financial interest disclosure (FID) form later?
A covered individual who is applying for a PHS-funded research project must ensure his or her financial interest disclosure statement is current at the time of application to the PHS entity. An individual who is new to the University and who is planning to participate in an on-going PHS-funded research project must submit a financial interest disclosure not later than the 30th day of after beginning employment.
12. I inadvertently failed to disclose one or more of my financial interests. What should I do?
You must disclose the financial interests immediately using the web-based Financial Interest Disclosure (FID) form. The Objectivity in Research Committee will determine if a FCOI exists, and if so, implement an interim management plan or implement other interim measures to ensure the objectivity of the research going forward.
13. What happens if my financial interests change?
A covered individual must submit or update a financial interest disclosure statement:
- not later than the 30th day after beginning employment, covering the 12 months preceding the date of disclosure;
- annually not later than the date mandated by the University;
- not later than the 30th day after acquiring a new financial interest that requires disclosure;
- and within 30 days from date of travel.
Visit http://www.utexas.edu/research/rsc/coi/fid_updates.html for instructions on updating your FID form.
14. Do I need to disclose the value and source of my financial interests?
Yes. You must disclose the name and principal address for the source and the monetary value of a financial interest within the following ranges:
- $0 - $4,999;
- $5,000 - $9,999;
- $10,000 - $19,999;
- amounts between $20,000 - $100,000 by increments of $20,000; or
- amounts above $100,000 by increments of $50,000.
15. I hold equity interest (i.e., stock/stock warrants/options) in a company, but do not know the monetary value. Do I need to disclose information about my equity interests and what should I disclose?
Yes. You must determine and disclose the percentage of equity ownership held in the company. If the percentage is unknown, determine and disclose the number of stock/stock warrants/options held.
16. Do I need to disclose salary paid to me by the University as an Investigator?
No. Salary, royalties, or other remuneration from your employment or appointment at the University are not included.
17. I transferred intellectual property rights to the University. Do I need to disclose the intellectual property rights?
No. You are not required to disclose salary, royalties, or other remuneration paid to you by the University if you are currently employed or otherwise appointed by the University, including intellectual property rights assigned to the University and agreements to share in royalties related to such rights.
18. Is writing a book considered “research?”
No. Writing and publishing a book is not research. However, if the book is related to the author(s) “institutional responsibilities” and there is a royalty stream associated with sale of the book, it would need to be disclosed.
19. I conduct social, behavioral, and/or educational research. I do not conduct biomedical research. Do I need to do the COI training and submit a financial interest disclosure (FID) form?
Yes. The COI training and disclosure requirement applies to all individuals responsible for the design, conduct, or reporting of research, regardless of funding source or field of study.
20. Do I need to disclose the occurrence of any reimbursed or sponsored travel related to my institutional responsibilities?
Yes. The regulation and University policy require covered individuals to disclose the occurrence of any reimbursed or sponsored travel (i.e., that which is paid on behalf of the Investigator and not reimbursed to the covered individual so that the exact monetary value may not be readily available), related to the covered individual’s institutional responsibilities. However, the disclosure requirement does not apply to travel that is reimbursed or sponsored by the following:
- a federal, state, or local government agency,
- an Institution of higher education as defined at 20 U.S.C. 1001(a),
- an academic teaching hospital,
- a medical center, or
- a research institute that is affiliated with an Institution of higher education.
21. If a faculty member gives an educational research presentation at an international conference funded by a non-U.S. company or institution of higher education, does honoraria or travel reimbursement from that presentation and/or consultation need to be reported?
Yes. Any exceptions to the regulations are applicable only to U.S. governmental agencies, institutions of higher education, academic medical centers and hospitals. This will almost certainly be an issue at the University due to a myriad of international collaborations. For example, when a disclosure is reviewed, reimbursed or provided travel from non-U.S. companies would be difficult to exclude under any circumstances due to the global nature of the business. However, travel reimbursed or provided by international institutions of higher education would be reviewed and may be determined not to represent an FCOI.
22. My department received a gift. Do I need to disclose funds I receive from this gift?
It depends. If the gifted funds are used for research purposes, you are required to disclose. If the gifted funds are used for non-research purposes, you are not required to disclose receipt of that gift under the policy on objectivity in research. However, receipt of gifts may be covered under other existing University policies.
23. Do I need to disclose travel that is paid for using funds from a sponsored grant or contract?
No. Travel paid with funds from a grant or contract processed through the Office of Sponsored Projects (OSP) and/or the Office of Industry Engagement (OIE) does not need to be disclosed.
24. Do I need to submit a disclosure form for every research project I am involved in?
No. A Covered Individual should only submit one financial interest disclosure (FID) form and update it annually or whenever changes occur. The form includes a section for listing all your research projects.
25. Does income from a non-profit organization need to be disclosed?
Yes. Federal regulations and University policy require the disclosure of income and interests from, and travel paid for by non-profit organizations, if it is related to your institutional responsibilities.
26. I sit on a NIH study section. Do I need to disclose the income that I receive?
No. You do not have to disclose income from serving on an NIH study section because it is a U.S. government agency.
27. Do I need to disclose prizes that I have received?
No. Prizes are not considered significant financial interests that require disclosure.
B. Training FAQs
1. If I previously completed FCOI training through CITI, do I need to also complete the training administered through University Compliance Services Compliance Training System (CTS)?
No. The FCOI training you completed through CITI will be applicable for four (4) years, after which time you will need to renew your training through CTS.
2. I would like to finish my FCOI training that I partially completed in CITI, but I cannot find it. What do I do?
The FCOI training is now administered through University Compliance Services. Visit the COI training webpage for instructions on completing the mandatory FCOI training.
3. I took the Responsible Conduct for Research (RCR) course in CITI that included a conflict of interest module. Do I need to take the Financial Conflict of Interest (COI) module administered through University Compliance Services Compliance Training System (CTS)?
Yes. The COI information contained in the RCR course is not the same as the new material required by the revised regulations and University policy. Complete the FCOI training course through Compliance Training System (CTS).
4. I took the CITI Human Subjects Research course (sociobehavioral or biomedical) to satisfy IRB requirements. Do I need to take the FCOI training module administered through University Compliance Services (UCS)?
Yes. FCOI training is different than the Human Subjects Research course. FCOI training is required in addition to the Human Subjects Research training.
5. I conduct social, behavioral, and/or educational research. I do not conduct biomedical research. Do I need to do the FCOI training?
Yes. The FCOI training is required by all individuals responsible for the design, conduct, or reporting of research, regardless of funding source or field of study.
6. My research is not funded by PHS. Do I need to complete the FCOI training?
Yes. The FCOI training is required by all individuals who are involved in the design, conduct, or reporting of human subjects research, regardless of funding or funding source.
If the research does not involve human subjects, individuals who are responsible for the design, conduct, or reporting of research must complete the FCOI training.
7. If I did the FCOI training when I was at another institution, do I have to do the training again?
It depends on whether or not you are a University faculty, staff, or student and your responsibilities or involvement in University research. lease review the Conflict of Interest guidelines for Co-Investigators, Collaborators, and Subrecipients.
8. I completed my FCOI training. How do I submit a Financial Interest Disclosure (FID) form?
You will receive an e-mail notification from the COI Program Coordinator with instructions for completing the FID form within approximately 1 to 2 business days after you complete the training. You can also visit our web site for instructions on How to Submit Your Financial Interest Disclosure (FID) form.
9. Does the FCOI training have an assessment or quiz?
10. The Compliance Training System indicates “None” under Modules Needed. What do I do?
You must select the “RC 410 Financial Conflict of Interest” course from the list of Optional Modules Available.
C. Financial Interest Disclosure FAQs
1. I completed my COI training. How do I submit a Financial Interest Disclosure (FID) form?
You will receive an e-mail notification from firstname.lastname@example.org with instructions for completing the FID form approximately 1 to 2 business days after you complete the training.
2. My internet browser does not allow me to view the FID because of pop-up blockers. What do I do?
Adjust your internet browser settings to allow pop-ups for spike.orsc.utexas.edu. Contact your IT department for assistance with pop-up allowance settings.
3. The disclosure form does not let me click the radial buttons or enter information. What do I do?
When you first open the disclosure form, make sure you select “Edit” when asked if you want to open the FID for editing.
4. I clicked on the FID ID, but nothing happened. What do I do?
First, make sure that your internet browser allows pop-up windows from spike.orsc.utexas.edu. The first window that appears will ask you if you want to open the form to edit. Select Edit. Next, the FID form will appear in a separate window. You can find this window by checking your taskbar.
5. My research projects were not imported from the Research Management System (RMS). What do I do?
RMS only exports information for funded research projects administered by OSP or OIE on which you are listed as the Principal Investigator. You must manually add information for projects on which you are a Co-PI or other research staff or if the research is not administered by OSP or OIE.
6. My unfunded research projects do not appear. What do I do?
Only funded research projects administered by OSP or OIE are auto-populated in the FID form. You must manually enter information for unfunded research projects or those not administered by OSP or OIE in the first table.
7. I am involved in several research projects. Do I need to list all of them?
List all research projects in which you are responsible for the design, conduct, or reporting. This may include research projects on which you are listed as a Principal Investigator, Co-Investigator, Faculty Sponsor, or research assistant.
8. RMS exported inaccurate and/or inactive research projects. What do I do?
Contact The Office of Sponsored Projects (OSP) at email@example.com to remove the research project from RMS, which will remove it from the FID form.
9. I looked at my FID form earlier, but did not submit. When I logged in again, I did not see the FID form. How do I find my FID to edit and submit it?
Hover your cursor over “FID Menu” and then “Individual” in the top left corner of the screen. Select “Individual.” This will bring you to your Individual home page where the FID Form number should be listed.
10. I cannot submit the FID form because it says I need to complete RC410 – Financial Conflict of Interest. I did the training already. What do I do?
eProtocol will not have a record of your training if you completed it on the same day that you tried to submit the FID form. Save your responses to the FID form and return one day later to submit the form.
11. I want to change a response to the Components section from Yes to No, but I can’t click the radio button. What do I do?
First, make sure that you select Edit when asked if you want to open the form to edit. Next, delete the previously added information from the Component sub-section (Involvement, IP/Royalties, Travel, Gift, Involvement, Position). When it is deleted, you should be able to change your response to the corresponding Component question.
12. Will I be notified when it is time to file a FID again?
You should update your FID form within 30 days of acquiring new financial interests that require disclosure. As the expiration date for the FID nears, eProtocol will send you automatic notifications 60 and 30 days prior to the expiration date.
13. I thought I submitted my FID form, but I am told that it was not received. How do I check to see if my FID form was successfully submitted?
First, run a Check on your FID form to identify any incomplete sections. This is located on the left-side menu within the FID form. If the Check identifies incomplete sections, return to those sections to address the incomplete areas. If the Check indicates the FID is complete, select the “Next” button which will take you to the Submit section. Then, Select the “Submit FID Form” button. Once the form is submitted, you will receive an automated confirmation e-mail.
14. The information on the Individual section is incorrect and the form will not let me edit. What do I do?
The information on the Individual section of the FID form is automatically exported from the University Directory and/or other University records. At this time, the information cannot be modified on the FID form.
15. I completed my FCOI training and received an e-mail instructing me to submit the FID. I misplaced the e-mail and cannot find the web address to access my FID.
Visit https://spike.orsc.utexas.edu/fid/ to log in to eProtocol and access your FID form.
16. When I tried to log in to eProtocol, I received a message indicating that my UT EID was not entitled to access the system and was referred to the Office of Research Support. Is this correct and what do I do?
Contact firstname.lastname@example.org regarding the error message you received. This will initiate the authorization process. The Office of Research Support will assist you through this process.
17. I received an e-mail notifying me that my FID was returned. I do not understand what I need to do.
You must log in to eProtocol and access your FID. Ensure that you select “Edit” in response to the pop-up window. Go to the “Return Notes” section of the FID form. Revise the form as instructed in the return notes. To re-submit the form, select “Submit” in the left side menu and select the "Submit FID Form" button.
18. I received an e-mail notifying me that my FID was returned because I need to describe the research I am involved in. I am not involved in any research at this time. What do I need to do?
In the “Research” section of the FID form, select the checkbox next to the statement, “I am not involved in research at this time (regardless of funding or funding source).” Save your response and re-submit the form. To re-submit the form, select “Submit” in the left side menu and select the "Submit FID Form" button.
Note: You are required to update your FID as soon as you become involved in research.
19. I responded to the return notes by revising my FID, but every time I click “Next” I am taken back to the Policy section. How do I submit the FID form?
Select “Submit” from the left side of the FID form and then select the “Submit FID Form” button. You will receive an automated confirmation e-mail immediately after successfully submitting the FID.
20. I thought I completed my FID, but when I checked the form, it says that it is incomplete. How do I complete the FID?
The check will identify the section that is incomplete and provide instructions in red. For example, if the policy section is identified during the check, you will need to go to the policy section to ensure that the checkbox toward the bottom of the window is marked. This certifies that you read the policy. Make sure that you select the “Submit FID Form” button to submit the FID.
In determining whether a financial interest should be disclosed, the covered individual should resolve the doubt in favor of disclosure.
Office of Research Support
PHS COI FAQs: http://grants.nih.gov/grants/policy/coi/coi_faqs.htm
PHS COI Policy: http://www.gpo.gov/fdsys/pkg/FR-2011-08-25/pdf/2011-21633.pdf