The University of Denver has an obligation to the public to conduct its activities transparently and with integrity. DU is committed to avoiding financial conflicts of interest that may compromise or appear to compromise the integrity and objectivity of research and the safety of human research subjects.
-
What is a conflict of interest?
An individual conflict of interest related to research arises when financial or other personal or professional considerations compromise, or have the appearance of compromising, an individual's professional judgment in proposing, conducting, supervising or reporting research. University researchers (faculty, staff and students) have an obligation to disclose outside activities when they maintain an interest (equity interest, management role or consulting income in excess of $1,000 per year) in an in an outside entity. Researchers must also disclose personal or professional relationships or collaborations with external entities that are impacted by the research being undertaken by the researcher.
-
Who must complete a conflict of interest (COI) disclosure?
All researchers who are proposing or have received funding external entity must make an annual disclosure of all real or potential conflicts of interest related to their institutional responsibilities, regardless of whether any of these interests give rise to an actual conflict of interest related to their research. The annual disclosure must be completed before a proposal is submitted, and any identified conflicts must be managed before an account can be established.
-
What conflict of interest training is required for researchers?
In addition to submitting an annual disclosure form, all DU researchers who receive funding from an external entity must complete all applicable conflict of interest, responsible conduct of research, research security, export control and foreign interference training prior to commencing or engaging in any funded research activity and must renew their training at least every four years. All training must be completed through the Collaborative Institutional Training Initiative (CITI) Program. For more information on the online CITI training, please click here.
Conflict of Interest Disclosure
University policy requires all researchers who receive externally funded awards to complete an annual Conflict of Interest Disclosure (COI) Form, complete a separate disclosure for any newly funded projects during the calendar year, and update a disclosure during the year if a potential conflict occurs or changes. All COI disclosures must be submitted electronically, utilizing the InfoEd system.
-
How do I complete disclosure for the first time?
All COI disclosures must be completed the electronic form produced by InfoEd, click here.
-
How do I update my current disclosure?
If a researchers conflict of interest changes throughout the year related to a proposed new project or current project, a new COI Disclosure must be completed using the electronic system.
-
Who must disclose?
- Any University employee that serves as a project director or principal Investigator and any other person, regardless of title or position, who is responsible for the design, conduct, or reporting of research funded by any federal agency, or who has submitted a proposal for such funding, which may include, for example, collaborators or consultants, must complete an annual disclosure form.
- Researchers also include any other individual (internal or external to DU) who are independently responsible for research design, conduct, or reporting (i.e. individual(s) who have the authority to make independent decisions about the direction of the research and the subsequent conclusions about the results and/or likely to be authors on manuscripts or to present research findings).
- Researchers who receive federally-funded awards, either as prime or pass-through awardee, must complete the annual disclosure and fulfill the required conflicts of interest training (Research Conflicts of Interest module) through the CITI program.
-
When must a disclosure be submitted?
| Timing |
Disclosure Timeframe |
| Initial disclosure |
All investigators must electronically submit the COI disclosure prior to engaging in research funded by the federal government of as required by the ORSP Research Conflicts of Interest Policy. |
| Within 30 days of a new SFI |
Investigators must update their disclosure within 30 days of acquiring a new significant financial interest (SFI) meeting disclosure requirements. |
| Annually |
Investigators must update their disclosure at least annually, even if acknowledging no change. |
