Investigators and Collaborators

All Covered Individuals, as defined by The University of Texas at Austin’s (University) policy for “Promoting Objectivity in Research by Managing, Reducing, or Eliminating Conflicts of Interest”, are required to complete Financial Conflict of Interest (FCOI) training and submit a Financial Interest Disclosure (FID) form if they are involved in University research, regardless of funding or funding source.

Who is a Covered Individual (CI)?

Per University policy, a CI is an individual who is responsible for the design, conduct or reporting of research.  The PI determines who meets the definition of a CI based on the individual’s responsibilities. Individuals who hold the following positions and titles often have responsibilities that meet the definition of a covered individual.

  • Principal Investigators (PI)
  • Co-Investigator
  • Faculty sponsor
  • Mentor
  • Research assistants

NOTE: If the research involves human subjects, a CI is an individual who is involved in the design, conduct, or reporting of research. Contact the Office of Research Support and Compliance at orsc@uts.cc.utexas.edu or 512-471-8871 if you have questions about whether or not your research involves human subjects.

Once the PI identifies who is a CI on a research project, the next step is to determine the appropriate training and disclosure requirements for each CI.

Requirements for University Covered Individual

University CIs must submit a FID form, which encompasses completion of FCOI training.

As part of the FID submission process, you will complete the Policy section, which provides training regarding applicable policies, regulations, and laws for promoting objectivity in research.

Click here to review and follow the instructions for submitting a FID form.

If you need to update your FCOI training or FID form, click here.

(Effective February 6, 2017, FCOI training is now housed within the FID form via the electronic submission system, eProtocol. This means that the FCOI training module is no longer available through the University Compliance Services Compliance Training System (CTS). Prior CTS completion records will be maintained and researchers are not required to re-take the FCOI training until the record expires or when their FID form expires, whichever occurs first.)

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
If you are conducting research on behalf of your home institution/entity

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. Complete Requirement A as outlined below.

Requirement A

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) and the non-University CI is compliant with the policy. The following steps must be addressed.

    1. An authorized representative must complete and send the below statement to coi@austin.utexas.edu (copying the IRB Program Coordinator and 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.

NOTE: If the institution/entity’s FCOI policy is determined to NOT meet the minimum requirements of the PHS regulations or 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.

Return to top.

If you are involved as an independent researcher

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.

Return to top.

If you are conducting research on behalf of your home institution/entity

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.

Registration in the FDP Clearinghouse may apply to you or complete Requirement A as outlined below.

Registration in the FDP Clearinghouse

The University will accept the institution/entity’s certification with The Federal Demonstration Partnership (FDP) Clearinghouse in lieu of compliance with Requirement A or B.*

* For projects that involve human subjects research, compliance with Requirement A will be necessary prior to IRB approval of the protocol.

Requirement A

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) AND the non-University CI is compliant with the policy. The following steps must be addressed.

  1. An authorized representative must complete and send the below statement to coi@austin.utexas.edu (copying the IRB Program Coordinator and 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.

NOTE: If the institution/entity’s FCOI policy is determined to NOT meet the minimum requirements of the PHS regulations or 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.

Return to top.

If you are involved as an independent researcher

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.

Return to top.