Investigators and Collaborators

All Researchers who are identified as Covered Individuals are required to complete a Financial Interest Disclosure form to disclose significant financial interests related to their institutional (University) responsibilities.

Per University policy HOP 7-1210, “Promoting Objectivity in Research by Managing, Reducing, or Eliminating Conflicts of Interest“, a Covered Individual is a person who is responsible for the design, conduct or reporting of research.

The Principal Investigator for a research project is expected to determine who meets the definition of a Covered Individual, based on the person’s responsibilities on the project and their level of independence in carrying out these responsibilities. Guidance for determining Who is a Covered Individual? is provided here.

Requirements for University Covered Individuals

University CIs must submit a Financial Interest Disclosure (FID) form prior to their involvement in research activities and must update their FID form at least annually, or within 30 days of acquisition of a new financial interest that requires reporting.

As part of the FID submission process, researchers complete a Policy section, which provides information regarding applicable policies, regulations, and laws for promoting objectivity in research at UT-Austin. Financial Conflict of Interest training is fulfilled when the CI completes and submits the FID form.

The University uses a web application (eProtocol FID) for Financial Interest Disclosure submission and review. Instructions for submitting your FID form can be found here:

Upon receipt of a new or updated FID form, the RSC reviews all disclosures and communicates with the investigator, as necessary, to determine if there is a disclosed financial interest that presents a financial conflict of interest with the investigator’s research activities. This process may involve the Objectivity in Research Committee. When a potential or perceived financial conflict of interest is identified, the RSC works with the investigator to manage or otherwise mediate the conflict of interest.

Requirements for Non-University Covered Individuals (Non-University CI)

Requirements are based on the research conducted. Select which of the following applies to you:

Human Subject Research Requirement IRB Approval

Individuals conducting human subjects research on behalf of their home institution/entity are contributing knowledge and expertise to the research project in association with the institution/entity where they are appointed or employed. This includes academic and research institutions outside of UT-Austin, and for-profit or non-profit entities. These individuals may complete Requirement A as outlined below.

Requirement A for Research Involving Human Subjects

If the home institution/entity has established an FCOI policy that meets the minimum requirements of the PHS regulations (45 CFR Part 94 and 42 CFR Part 50, Subpart F), as evidenced by registration in the FDP Clearinghouse (The Federal Demonstration Partnership Clearinghouse), the following steps should be taken.

  1. If Covered Individuals at the outside institution/entity are engaged in human subjects research using identifiable data as part of the study, the collaborating UT investigators should complete a study site application form: Site Specific Application for Relying on UT IRB. This form requires certification by an IRB Contact at the relying institution, allowing the outside entity to certify that the non-UT collaborators are compliant with FCOI policies and to confirm that any financial conflict of interest with the study has been identified and managed.
  2. The completed Site Specific Application must be submitted to the UT IRB through IRB Access, with a copy also sent to coi@austin.utexas.edu. The message to coi@austin.utexas.edu should also include a copy of, or a link to the institution/entity’s FCOI policy.

NOTE: If the institution/entity’s FCOI policy is determined to NOT meet the minimum requirements of the PHS regulations or if the institution/entity does not have an FCOI policy, the non-University Covered Individual must comply with Requirement B.

Requirement B

When a Covered Individual’s home institution/entity does not have a PHS-compliant FCOI policy, the investigator is required to complete the University of Texas at Austin Financial Interest Disclosure form. The investigator should follow the process described below:

  1. Obtain a guest UT EID or find/unlock your prior assigned UT EID. Ensure an active and current e-mail address is listed in your EID profile.
  2. Request eProtocol Authorization: Send an e-mail to The Office of Research Support and Compliance (orsc@uts.cc.utexas.edu) with the following information:
    Subject Line: Authorization Request - eProtocol FID
    Message:

    1. Your First and Last Name
    2. Your UT EID
    3. First and Last Name of the University of Texas at Austin researcher with whom you are collaborating
    4. Number of anticipated years you will be involved in the project
  3. Submit a FID Form: After The Office of Research Support and Compliance confirms authorization, submit a FID form by following the instructions at this website. Investigators should log in with their UT EID and password here: https://spike.orsc.utexas.edu/fid/. Outside collaborators should keep in mind that they are only required to disclose financial interests that would reasonably appear to be related to their responsibilities or work on the UT-Austin research project.

Research collaborators or outside consultants conducting UT-Austin research as independent investigators are those who are providing knowledge and expertise to a research project, but NOT acting on behalf of their home institution/entity. In these cases, the non-University Covered Individual must comply with Requirement B as outlined below.

Requirement B

Follow the below steps in the order described:

  1. Obtain a guest UT EID or find/unlock your prior assigned UT EID. Ensure an active and current e-mail address is listed in your EID profile.
  2. Request eProtocol Authorization: Send an e-mail to The Office of Research Support and Compliance (orsc@uts.cc.utexas.edu) with the following information:
    Subject Line: Authorization Request - eProtocol FID
    Message:

    1. Your First and Last Name
    2. Your UT EID
    3. First and Last Name of the University of Texas at Austin researcher with whom you are collaborating
    4. Number of anticipated years you will be involved in the project
  3. Submit a FID Form: After The Office of Research Support and Compliance confirms authorization, submit a FID form by following the instructions at this website. Investigators should log in with their UT EID and password here: https://spike.orsc.utexas.edu/fid/. Outside collaborators should keep in mind that they are only required to disclose financial interests that would reasonably appear to be related to their responsibilities or work on the UT-Austin research project.

Sponsored Research

If you are conducting research on behalf of your home institution/entity, you are contributing your knowledge and expertise to the research project in association with the institution/entity where you are appointed or employed. This applies to any non-University institution/entity, even other UT System academic and health institutions.

If the home institution/entity has established an FCOI policy that meets the minimum requirements of the PHS regulations (45 CFR Part 94 and 42 CFR Part 50, Subpart F), as evidenced by registration in the FDP Clearinghouse, the University will accept the institution’s or entity’s certification with The Federal Demonstration Partnership (FDP) Clearinghouse in lieu of compliance with Requirement A or B.*

* For sponsored projects that involve human subjects research, compliance with Requirement A for Human Subjects Research (outlined above) will be necessary prior to IRB approval of the protocol.

Requirement A for Sponsored Research that does not involve Human Subjects

In some cases, the Covered Individual’s home institution/entity has established a FCOI policy that meets the minimum requirements of the PHS regulations (45 CFR Part 94 and 42 CFR Part 50, Subpart F), but the entity’s FCOI policy is not certified with the FDP Clearinghouse. In this case, the following steps can be taken.

  1. An authorized representative must complete and send the below statement to coi@austin.utexas.edu, copying Office of Sponsored Projects (OSP) staff, as applicable, via e-mail or letterhead. [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.”
  2. Include a copy of or a link to the institution/entity’s FCOI policy for review.

If the FCOI policy of the Covered Individual’s home institution/entity is determined to NOT meet the minimum requirements of the PHS regulations or if the institution/entity does not have an FCOI policy, the non-University CI must comply with Requirement B.

Requirement B

Follow the below steps in the order described:

  1. Obtain a guest UT EID or find/unlock your prior assigned UT EID. Ensure an active and current e-mail address is listed in your EID profile.
  2. Request eProtocol Authorization: Send an e-mail to The Office of Research Support and Compliance (orsc@uts.cc.utexas.edu) with the following information:
    Subject Line: Authorization Request - eProtocol FID
    Message:

    1. Your First and Last Name
    2. Your UT EID
    3. First and Last Name of the University of Texas at Austin researcher with whom you are collaborating
    4. Number of anticipated years you will be involved in the project
  3. Submit a FID Form: After The Office of Research Support and Compliance confirms authorization, submit a FID form by following the instructions at this website.

If you are involved in research as an independent researcher (i.e., collaborator or consultant that is paid or unpaid), you are providing your knowledge and expertise to a research project, but NOT acting on behalf of your home institution/entity. Complete Requirement B as outlined below.

Requirement B

Follow the below steps in the order described:

  1. Obtain a guest UT EID or find/unlock your prior assigned UT EID. Ensure an active and current e-mail address is listed in your EID profile.
  2. Request eProtocol Authorization: Send an e-mail to The Office of Research Support and Compliance (orsc@uts.cc.utexas.edu) with the following information:
    Subject Line: Authorization Request - eProtocol FID
    Message:

    1. Your First and Last Name
    2. Your UT EID
    3. First and Last Name of the University of Texas at Austin researcher with whom you are collaborating
    4. Number of anticipated years you will be involved in the project
  3. Submit a FID Form: After The Office of Research Support and Compliance confirms authorization, submit a FID form by following the instructions at this website.