COI FAQs

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 and Compliance website.

The “Promoting Objectivity in Research by Managing, Reducing or Eliminating Financial Conflicts of Interest” policy is effective as of August 24, 2012 and requires researchers to submit a Financial Interest Disclosure form to RSC.

We encourage investigators to submit information related to the “Conflicts of Interest, Conflicts of Commitment, and Outside Activities” policy (UTS 180/HOP 5-2011) through the UT System Outside Activity Portal. These submissions are routed to your direct supervisor for review and approval. You should review the policy for UTS 180/HOP 5-2011 and can contact the Office of the Provost to confirm whether an Outside Activities disclosure is appropriate.

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.

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. Guidance for determining “Who is a Covered Individual?” is provided here.

A “Covered Family Member” includes:

1. a spouse;
2. a dependent child or stepchild or other dependent, for purposes of determining federal income tax liability during the period covered by the disclosure statement;
3. 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.

“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).

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)

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 a Financial Conflict of Interest with University research. Not all financial interest disclosures will result in a conflict of interest determination. If a disclosed financial interest is determined to present an actual or perceived financial conflict of interest in research, RSC will work with the investigators to develop a FCOI management plan. This process may involve the input of the Objectivity in Research Committee.

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.

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.

Visit https://research.utexas.edu/ors/conflict-of-interest/update-your-fid-form/ for instructions on updating your FID form. You can log in to eProtocol FID (https://spike.orsc.utexas.edu/fid/) and update your FID form anytime.

Changes to existing financial interests or newly acquired financial interests must be disclosed within 30 days from the date of acquisition. This applies to payment, equity, IP/royalties, gifts, and fiduciary positions.

Visit https://research.utexas.edu/ors/conflict-of-interest/update-your-fid-form/ for instructions on updating your FID form.

Yes. You must disclose the name and principal address for the source and the monetary value of a financial interest (payment, equity, IP/royalties, and gifts) within the following ranges:

1. $0 - $4,999;
2. $5,000 - $9,999;
3. $10,000 - $19,999;
4. amounts between $20,000 - $100,000 by increments of $20,000; or
5. amounts above $100,000 by increments of $50,000

The value of reimbursed or sponsored travel is not requested.

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.

No. Salary, royalties, or other remuneration from your employment or appointment at the University are not included.

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.

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.

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.

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.

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.

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.

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.

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.

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.

No. You do not have to disclose income from serving on an NIH study section because it is a U.S. government agency.

No. Prizes are not considered significant financial interests that require disclosure.

It is important to disclose plans for a startup company to both the Office of Technology Commercialization and the Office of Research Support and Compliance (Conflict of Interest office). Please see this Info Sheet for investigators involved in startup companies and/or SBIR or STTR research proposals.

Visit our webpage for instructions on how to adjust your pop-up settings.

When you first open the disclosure form, make sure you select “Edit” when asked if you want to open the FID for editing.

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.

RMS only exports information for proposals and sponsored projects administered by OSP or OIE on which you are listed as the Principal Investigator or Co-PI. You must manually add information for sponsored projects on which you are involved (but are not listed as PI or Co-PI), or for any research is not administered by OSP or OIE.

Only research proposals and 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.

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.

Contact The Office of Sponsored Projects (OSP) at osp@austin.utexas.edu to remove the research project from RMS, which will remove it from the FID form.

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.

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.

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 days, 30 days, and 1 day prior to the expiration date.

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.

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.

Contact orsc@uts.cc.utexas.edu regarding the error message you received. Provide the Office of Research Support and Compliance with the four points of requested information that are displayed in the error message. This will initiate the authorization process. The Office of Research Support and Compliance will assist you through this process.

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.

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.

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.

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.

You can access and download a copy of the approval e-mail that you received when you filed your FID form with our office. The copy of this communication is located in the history of your approved FID form.

• Use your UT EID and password to log in to eProtocol at: https://spike.orsc.utexas.edu/fid
• Select the FID ID listed under “Accepted FIDs.”
• Open in View Mode. The FID form will open at the Policy section.
• Select “History” using the blue menu on the left side of the FID form. The history is organized by date, with the most recent communication listed at the top.
• Select “Disclosure on File: FID-XXXX-XXXXX, LastName,FirstName.” It will open or save as a .pdf file.

Send this downloaded file to the requester.