Disclosure Submission Process

• Electronic Conflict of Interest (eCOI) System
• Privately Funded Research
• PHS Funded Research (Including Adopted Organizations)
• Non-PHS Government Funded Research
• Human Subject Research
• Department Funded Research
• FAQs

General Information

Who Must Disclose and Selecting the Correct Form

State and Federal conflict of interest laws, as well as university policy, requires investigators to complete financial interest disclosures when a sponsored program is proposed. The sponsor of your research dictates the type of disclosure (if any) that you must complete, with additional information required if the research involves human subjects.

Definition of PI and Investigator:

Principal Investigator (PI) – has primary responsibility for the design, conduct, or reporting of sponsored research or educational activities conducted in whole or in part at the University.

Investigator – may be any person, other than the PI, has responsibility for the design, conduct or reporting of sponsored research or educational activities conducted in whole or in part at the University.

When a research project is sponsored by a non-governmental entity (e.g. private entities):

• All PIs must disclose their financial interests in the sponsor of the research on a Form 700-U.
• Completion of the 700-U is not required if the State has placed the sponsor on the exempt list.
• If the project involves human subjects, the PI/Investigators must disclose any significant financial interests (SFIs) related to the research project on a Form 800.
• The initial disclosure, all interim, and supplemental disclosures must be submitted in accordance with the Policy and Procedure Manuals (PPM):
  •  PPM 230-05 (Individual Conflicts of Interest Involving Research)
  • PPM 230-07 (Public Health Service Regulations on Objectivity in Research).

When a research project is sponsored by a non-PHS governmental entity (e.g. NSF, CIRM), certain other entities (see exempt list), or is human subject research that is FDA-regulated, the PI/Investigators must:

• All PIs and Investigators must disclose their SFIs that are related to the sponsored research project on a Form 800.
• All PIs and Investigators must disclose any related SFIs of their spouses/domestic partners and dependent children on a Form 800.
• The initial disclosure, and all interim and supplemental disclosures must be submitted in accordance with the the Policy and Procedure Manuals (PPM):
  • PPM 230-05 (Individual Conflicts of Interest Involving Research)
  • PPM 230-07 (Public Health Service Regulations on Objectivity in Research).

When a research project is sponsored by a PHS agency (e.g. NIH, AHRQ), or any entity that has adopted the PHS rules, you must:

• All PIs and Investigators must disclose their SFIs, and those of his or her spouse or registered domestic partner, and dependent children on a PHS Form.
• See the list of sponsors that require compliance for PHS Regulations.
• The initial disclosure, and all annual disclosures must be submitted in accordance with the the Policy and Procedure Manuals (PPM):
  • PPM 230-07 (Public Health Service Regulations on Objectivity in Research).