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The Office of Research Support (ORS) does not administer or oversee HOP policy 5-2011 or training related to the policy. ORS administers HOP policy 7-1210, “Promoting Objectivity in Research by Managing, Reducing or Eliminating Financial Conflicts of Interest” so if you conduct research and have:

  1. Not submitted a Financial Interest Disclosure (FID), you will need to complete mandatory training and file a FID. Instructions for completing these requirements are located at http://www.utexas.edu/research/rsc/coi/training.html.
  2. Previously submitted a FID, you are not required to complete additional training nor re-disclose the same information to comply with the UTS 180/HOP 5-2011 policy requirements.   However, you may have other responsibilities under that policy.

HOP policy 5-2011 QUESTIONS? Contact the Provost’s Office evpp_coi@austin.utexas.edu or call Mike Kerker, Associate Vice Provost at (512) 471-2694.

Proposals, Awards, and Contracts Guidance

The following information outlines the Institutional Review Board (IRB), Office of Sponsored Projects (OSP), and Office of Industry Engagement (OIE) approval processes as relates to compliance with the University policy for promoting objectivity in research.


IRB Requirements for Human Subjects Research

The IRB requires the completion of financial conflict of interest (FCOI) training and submission of a financial interest disclosure (FID) form by all Covered Individuals involved in human subjects research. The covered individuals must be identified on the IRB protocol. Examples of roles, positions, or titles of Covered Individuals include but are not limited to:

  • Principal Investigators (PI)
  • Co-Investigators (Co-Is)
  • Faculty sponsors
  • Mentors
  • Research Assistants

The Office of Research Support and the IRB will NOT commence the review of a protocol if any listed Covered Individual has not completed the training or disclosure requirements.

Notify the IRB Program Coordinator as soon as all Covered Individuals have addressed the requirements. This is applicable to any Exempt, Expedited, or Full Board study. It is important that these requirements are addressed prior to the submission of any new, amendment, or continuing review applications to prevent delays.

Contact the Office of Research Support at (512) 471-8871 or orsc@uts.cc.utexas.edu with questions about IRB requirements.


OSP and OIE Requirements for Proposal and Award Actions, Including Industrial Associate Program (IAP) or Research Participation Agreement (RPA) Actions, Gifts or Other Types of Research Projects

OSP requires completion of financial conflict of interest (FCOI) training and submission of a financial interest disclosure (FID) form by Covered Individuals as outlined below. PIs, Co-PIs, and Co-Is are automatically considered Covered Individuals. It is the responsibility of the Contact PI to make the determination as to whether other individuals, such as post docs, graduate students, technical staff, and consultants are considered Covered Individuals.

At the time of proposal for PHS funding (direct or as pass-thru):

  • Proposal Specialists at The University of Texas at Austin will verify that all Covered Individuals on a PHS funded project
    • Have completed the required COI training;
    • Have submitted a current financial disclosure
    • Per PHS policy, proposals may not be submitted for PHS funded projects if these requirements have not been met.

      NOTE: If a Significant Conflict of Interest exists, the Proposal Review Form should reflect such interests and a statement should be included in the proposal that discloses those interests.

At the time of any award:

  • Grants and Contracts Specialists at The University of Texas at Austin will verify that all Covered Individuals on any funded project
    • Have completed the required COI training;
    • Have a current financial disclosure that has been reviewed and approved; and
    • If a conflict of interest exists, that a Management Plan has been approved that includes the project.

      NOTE: Access to funds will be withheld until a Management Plan is approved. This includes authorizations for credit.

Compliance throughout the life of the project:

  • The Contact PI is responsible for informing the appropriate office (OSP or OIE) of any changes to Covered Individuals.
  • Covered Individuals
    • Must disclose to The University of Texas at Austin any financial interests in accordance with the policy during the course of the funded project.
    • Must certify annually whether there have been any changes to conflict of interest status.
    • Are required to renew their training every four years.

Contact the Office of Sponsored Projects at (512) 471-6424 or osp@austin.utexas.edu with questions about OSP requirements.

Contact the Office of Industry Engagement at (512) 471-3866 or industry@austin.utexas.edu with questions about OIE requirements.