Federal regulations and university policy outline conflict of interest disclosure requirements for faculty, staff, and students involved in the design, conduct, or reporting of research. Completion of required forms allow ORA to determine whether a Significant Financial Interest constitutes a financial conflict of interest and requires a management plan.
University Policy 54 governs conflict of disclosure and managements for all university personnel regardless of funding source.
The Office of Research Administration also utilizes Supplemental Procedures for Externally Funded Projects.
The Office of Research Administration requires every PI currently submitting a proposal or receiving an award to complete a Project Specific Conflict of Interest Form.
Investigators who receive funding from a Public Health Service agency (includes NIH,
CDC, HRSA, etc)must also disclose any reimbursed or sponsored travel to the ORA prior
to the submission of their project to the external agency. The ORA will maintain the
Disclosure of Reimbursed or Sponsored Travel form (below), in confidence, for at least
three years from the date the final expenditure report is submitted to the agency.
Investigators must update the Disclosure of Reimbursed or Sponsored Travel Form with
the ORA at the following intervals:
(a) within thirty days of acquiring a new reimbursed or sponsored travel opportunity; and
(b) annually within the period of the award
All externally funded investigators must undergo conflict of interest training through CITI Programs every four years. Instructions for registering for the CITI program and signing up for the course can be found at