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.

The IRB requires the submission of a Financial Interest Disclosure (FID) form by all Covered Individuals involved in human subjects research. FCOI training is held within the FID form submission process. The Covered Individuals must be identified on the IRB protocol. Examples of roles, positions, or titles of Covered Individuals may include but are not limited to:

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

The Office of Research Support and Compliance 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 and Compliance at 512-471-8871 or with questions about IRB requirements.

OSP requires completion of the Financial Interest Disclosure (FID) form by Covered Individuals as outlined below. FCOI training is held within the FID form submission process. 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 submitted a current Financial Interest Disclosure form
    • Per PHS policy, proposals may not be submitted for PHS funded projects if this requirement has 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 a current Financial Interest Disclosure form that has been reviewed and approved.
    • If an investigator’s FID form is approved with a FCOI management plan in place, a Proposal Specialist will contact the COI Office to request a FCOI project review. The COI Office will determine whether the funded project is related to the investigator’s financial conflict of interest, and if so, will ensure that the financial conflict of interest is appropriately addressed by the FCOI management plan. This often involves communication with the investigators who have a managed conflict of interest. NOTE: Access to funds will be withheld until a FCOI project review is completed. 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.

Contact the Office of Sponsored Projects at 512-471-6424 or with questions about OSP requirements.

Contact the Office of Industry Engagement at 512-471-3866 or with questions about OIE requirements.

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