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.
College Deans can run an ICON report that indicates all personnel who has submitted a certification in ICON. This is a starting point to determine if a Conflict of Interest Certification may be required. Review Instructions for Accessing the Dean’s report (PDF).
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 at least annually in the ICON for COI system. 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:
- Remuneration in excess of $5,000 from a publicly-traded entity during the preceding 12 months. For purposes of this definition, remuneration includes salary and any payment for services not otherwise identified as salary (e.g., consulting fees, honoraria, paid authorship)1;
- Equity interest (stock, stock options, or other ownership interest) in a publicly traded company valued in excess of $5,000 at the time of certification;
- Any combination of the above two items (equity and income) that exceeds $5,000 during the preceding 12 months;
- Any amount of equity (stock, stock options, or other ownership interest) in a non-publicly traded entity, including a start-up company;
- Remuneration that exceeds $5,000 from a non-publicly traded entity in the past 12 months, or
- Intellectual property rights and interests (e.g. patents and copyrights), upon receipt of such income related to such rights and interests Income related to intellectual property rights in excess of $5,000 paid by any source other than the Investigator's current Institution.
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, or an Institution of higher education within the United States1 as defined at 20 U.S.C. 1001(a), an academic teaching hospital, a medical center, or a research institute that is affiliated with an Institution of higher education,
- Income from investments in mutual funds or retirement accounts, as long as the Investigator does not make the investment decisions,
- Income from service on advisory committees or review panels for a federal, state or local government agency or Institution of higher education within the United States1 as defined at 20 U.S.C. 1001(a), an academic teaching hospital, a medical center, or a research institute that is affiliated with an Institution of higher education, 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
Log into ICON from your Access UH and follow these instructions (PDF) or your can view a video.
|Primary Appointment||Required Signatory if Significant Financial Interest is Disclosed|
|Tenure track academic faculty appointments||Department Chair|
|Non-tenure track research faculty appointments||Department Chair|
|Staff & students employed by an academic department or college||Department Chair|
|Staff & students employed by a Division of Research Center||Department Chair|
|Tenure track academic faculty appointments affiliated with a Division of Research Center||Department Chair|
|Non-tenure track research faculty appointments with a Division of Research Center||Center Director|
|Department Chair||College Dean|
|Division of Research Center Directors||College Dean|
|Provost, VP for Research||President
Department Chair (if applicable)
|President||Board of Regents|
|College of Social Work||Assoc. Dean for Research|
|College of Architecture||Assoc. Dean for Research|
|College of Law||Assoc. Dean for Research|
|College of Hotel/Restaurant Management||Assoc. Dean for Research|
|College of Optometry||Assoc. Dean for Research|
|College of Nursing||Assoc. Dean|
|Academic Affairs (without department/college affiliation)||Provost|
|College of Business (Small Business Development Center only)||Sr. Assoc. Dean for Faculty|
Those faculty appointments with dual assignments require review by their primary appointment and are the responsibility of that college/department.
There are some additional exceptions to dual appointments. Contact the COI office for clarification at firstname.lastname@example.org.
1 Investigators, including subrecipient Investigators, must disclose all financial interests received from a foreign Institution of higher education or the government of another country (which includes local, provincial, or equivalent governments of another country).
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)