Who must complete a certification?
All academic staff members meeting the definition of Investigator as defined by University of Houston policy must certify their knowledge of and compliance with this policy by completing a Conflict of Interest Certification. An investigator is defined as the project director or principal Investigator, and any other persons, regardless of title or position, who are responsible for the design, conduct, or reporting of research or educational activities funded or proposed for funding. Therefore, the policy can apply to collaborators, consultants, post-doctoral fellows, graduate students, and others who meet the threshold for responsibility. At a minimum, all individuals listed as an investigator or key personnel on a research project must file a certification, however it is the responsibility of the PI to determine if other research team members meet this threshold based on their role in the research.
Compliance Guidance: Consider all personnel designing, conducting, or reporting research.
- Principal investigators, co-investigators, and key personnel listed on a proposal always meet this threshold.
- Other positions (for example: study coordinators, statisticians, and non-paid personnel) may also meet this threshold based on their role in the research.
- If you are a collaborator or sub-recipient/subcontractor engaged in research awarded to another institution, certification under the UH policy is required.
Business Offices can run an RD2K report that indicates all personnel listed on proposals and grants. This is a starting point to determine if a Conflict of Interest Certification may be required. See instructions.
When is certification required?
All academic staff members who meet the definition of Investigator (as defined above) must provide certification of their knowledge of and compliance with this policy on an annual basis, no later than October 1 of each year. In addition to the annual requirement, the acquisition or discovery of new significant financial interests requires disclosure within 30 days (see Changes/Updates to Financial Interest). Current financial interests should also be reconsidered for potential conflict when new research is proposed for funding and disclosed. This certification must occur prior to and within the same fiscal year as the submission of a proposal for funding.
What must be certified and disclosed?
To screen for situations that require further review, all Significant Financial Interests (SFIs) that may appear to be related to your research or institutional responsibilities must be disclosed. Disclosure is required if such an interest is held by you, your spouse, or your dependent children.
Common sense should prevail in the interpretation of these provisions. That is, if a reasonable, disinterested person would question the relationship (i.e. the interest may affect or be affected by the activity), it should be disclosed. Significant financial interests include:
- Income in excess of $10,000 ($5,000 for Public Health Service (PHS)-funded Investigators)1 from a publicly-traded entity during the last 12 months,
- Stock in a publicly traded company valued in excess of $10,000 ($5,000 for PHS-funded Investigators) at the time of disclosure,
- A combination of the above two items (stock and income) that exceeds $10,000 ($5,000 for PHS-funded Investigators) during the preceding 12 months,
- Any amount of equity (stock, stock options, or other ownership interest) in a non-publicly traded entity, such as a start-up company,
- Compensation that exceeds $5,000 from a non-publicly traded entity in the past 12 months, or
- Income related to intellectual property rights paid by any source other than the Investigator's current Institution that will exceed $10,000 within the next 12 months.
IMPORTANT: Some non-federal funding agencies require compliance with the lower thresholds set forth by the PHS policy2; review and consider your agency’s requirements when providing a conflict of interest certification.
The following DO NOT require disclosure
- Salary, royalties, or other remuneration paid to the Investigator from the Institution that currently employs the Investigator (although any financial interest in the company licensing the technology (e.g. equity, ownership, leadership role) must be disclosed.)
- Income from seminars, lectures, or teaching engagements sponsored by, a federal, state, or local government agency; a U.S. Institution of higher education; or a research institute affiliated with such, a medical center, or an academic teaching hospital,
- Income from investments in mutual funds or retirement accounts, as long as the Investigator does not make the investment decisions,
- Income for services (e.g., honoraria, advisory committees, and review panels) and travel expenses paid by a federal, state, or local government agency; a U.S. Institution of higher education; or a research institute affiliated with such, a medical center, or an academic teaching hospital, or
- Small Business Innovative Research (SBIR) and Small Business Technology Transfer (STTR) Program Phase I applications and awards. [Note: Although disclosure is not required under the PHS regulations for Phase I, it is highly recommended so that potential conflicts are understood and a plan is in place to manage them prior to the submission of Phase II. Such financial interests should still be addressed in consent forms for human subjects).
How to certify and disclose
- See the COI certification form.
- If one or more of the screening questions on the certification form is answered “yes,” a disclosure is required. If all answers are “no,” go directly to Step 3.
- Obtain all required signatures from your Chair, Center Director, College Dean acknowledging that to the best of their understanding all information submitted is accurate and they are not aware of any other potential conflicts that would necessitate further review.
Signing the Form: Conflict of interest forms must be signed by the Investigator and other signatories as follows:
- Handwritten signature
- Signature capture device (including Adobe "use as webcam" and Adobe "draw my signature")
- Adobe certificate
- Adobe “use an image” or placement of a .pdf signature
- Adobe “type my signature”
- Allowing a delegate to sign
For almost all submissions, the signatories on the Conflict of Interest Certification will be the investigator’s Department Chair as the first acknowledgment and College Dean for the second. There are, however, some exceptions (see table below).
Ensure your certification is reviewed and signed by the correct individuals and all the appropriate acknowledgement boxes have been checked:
|You are:||Signatory 1||Signatory 2|
|Tenure track academic faculty appointments||Department Chair||College Dean|
|Non-tenure track research faculty appointments||Department Chair||Center Director|
|Staff & students employed by an academic department or college||Department Chair||College Dean|
|Staff & students employed by a Division of Research Center||Department Chair||Center Director|
|Tenure track academic faculty appointments affiliated with a Division of Research Center||Department Chair||College Dean|
|Non-tenure track research faculty appointments with a Division of Research Center||Center Director||VC/VP for Research and Technology Transfer|
|Department Chair||College Dean||Provost|
|Division of Research Center Directors||College Dean||VC/VP for Research and Technology Transfer|
|College Dean||Provost||VC/VP for Research and Technology Transfer|
There are some additional exceptions to dual appointments. Contact the COI office for clarification at firstname.lastname@example.org.
- Once all signatures have been obtained, documents should be uploaded to RD2K. All Department Business Administrators have access to RD2K. Refer to these instructions to access and upload the documents (CougarNet credentials required).
1 Administration for Children and Families, Administration for Community Living/Administration on Aging, Agency for Health Care Research & Quality (AHRQ), Agency for Toxic Substances and Disease Registry (ATSDR), Centers for Disease Control & Prevention (CDC), Food and Drug Administration (FDA), Health Resources and Services Administration (HRSA), Indian Health Service (HIS), National Institutes of Health (NIH), Substance Abuse and Mental Health Services Administration (SAMHSA), Office of Global Affairs, Office of the Assistant Secretary for Health (OASH), Office of the Assistant Secretary for Preparedness and Response (ASPR)
2 Alliance for Lupus Research (ALS), American Asthma Foundation (AAF), American Cancer Society (ACS), American Heart Association (AHA), American Lung Association (ALA), Arthritis Foundation (AF), Juvenile Diabetes Research Foundation International (JDRF), Lupus Foundation of America (LFA), Susan G. Komen Breast Cancer Foundation, Bill and Melinda Gates Foundation, Muscular Dystrophy Association of America, Association for Research in Otolaryngology (ARO)