Who Needs to Disclose
All faculty and PI-eligible employees disclose Significant Financial Interests (SFI) and other outside activities at least annually by completing or updating the Disclosure Profile in UTRMS-COI. Disclosure is required:
- Within 30 days of initial employment
- Prior to the submission of an application for research funding
- When identified as a covered individual on an IRB proposal
- At least annually
- Within 30 days of acquiring a new activity requiring disclosure
All other UT staff (non-research staff) see the UT Austin Human Resources Outside Employment page.
Additional COI Requirements for Researchers
In order to help identify potential conflicts of interest related to research, Principal Investigators and other key personnel (covered individuals) on sponsored research or IRB protocols must update or certify their disclosures more frequently. A covered individual is a researcher who has the authority to make independent decisions related to the design, conduct or reporting of University research. Read more about determining who is a covered individual.
At the time a new sponsored project is awarded or when submitting a new IRB protocol, covered individuals must certify that the Disclosure Profile in UTRMS-COI is accurate and complete.
External research collaborators on subawards or named on IRB protocols may also need to disclose financial interests. Read FCOI Requirements for Non-UT Collaborators for details.
Financial Conflict of Interest Training
Required FCOI training is linked from the UTRMS-COI disclosure system; the training module includes a short video and four related questions. The Instructions and Policies page includes a link to the training module, and disclosers are not able to set up a COI Disclosure Profile without certifying that they have completed the appropriate training.
FCOI training expires after 3 years, and while researchers are not notified immediately when training expires, annual disclosure reviews and project specific COI certifications cannot be completed when training is expired.
What Requires Disclosure
There are four main categories of disclosures:
- Personal financial interests
- Outside activities
- Substantial foreign relationships or engagements
- Research support (monetary or in-kind) that is not managed through UT Austin sponsored projects
Common Disclosure Scenarios
| If You | You Should | Example and Guidance |
|---|---|---|
| Are paid to consult with an outside organization... | Request prior approval through UTRMS-COI and disclose it on your COI Disclosure Profile. | Example: Serving on a company’s Scientific Advisory Board or providing expert testimony. |
| Are traveling and a person or entity other than UT pays for your travel or reimburses you personally... | Disclose it on your COI Disclosure Profile. | Example: A company paid for your flights and hotel to attend a conference. Prior approval is not required before attending and presenting talks at scholarly colloquia or conferences, but outside travel support must be included on your Disclosure Profile following the trip. |
| Have involvement in a start -up company (co-founder, manager, advisor) and ownership interest in the company... | Request prior approval through UTRMS-COI and disclose it on your COI Disclosure Profile. | Even if the company has no value, any equity interest must be disclosed. Any management, executive leadership or other fiduciary position with an outside entity must be disclosed. |
| Are an investor or stockholder (any equity interest) in a private or publicly-traded company where the business interests would reasonably appear to be related to your professional expertise... | Disclose it on your COI Disclosure Profile. | Don’t disclose mutual funds or retirement accounts where you do not directly control the investment decisions. You don’t need to monitor and disclose daily fluctuations in the value of stock. |
| Are involved in sponsored research that is not administered and managed by a UT sponsored projects office... | Request prior approval through UTRMS-COI and disclose it on your COI Disclosure Profile. | Example: Named as key personnel on a grant submitted through another institution; serving as investigator or consultant for research projects outside UT. |
| Hold an academic or visiting scholar appointment with another institution (domestic or foreign) or provide teaching services to an outside entity… | Request prior approval through UTRMS-COI and disclose it on your COI Disclosure Profile. | Examples: Having an adjunct, honorary, visiting or other title with a foreign or domestic organization; participating in a foreign talent program. |
| Have research support from a foreign entity... | Disclose it on your COI Disclosure Profile. | Example: Receiving support outside of UT from foreign governments, foreign academic institutions or other foreign organizations, including laboratory space, equipment, personnel (graduate fellowships, visiting scholars), materials or other in-kind support. |
| Have a spouse, partner or dependent who participates in any of these Common Scenarios... | Disclose it on your Disclosure Form. | Disclose activities of immediate family members as you disclose your own activities. |
Where to Disclose
UT Austin uses UTRMS-COI for financial interest disclosures and outside activity pre-approval requests. The system sends email notifications to individuals when the initial disclosure or a research certification is required. Disclosure in UTRMS-COI is not possible without an invitation. After completing a Disclosure Profile Update for the first time, faculty and staff can update their profile at any time.
Instructions for completing/updating the Disclosure Profile can be found in the Disclosure Profile User Guide. For problems accessing the Disclosure Profile in the portal, please email COI@austin.utexas.edu.