Sec. 1 Applicability
This procedure applies to researchers at the University of Texas at Dallas (“UTD”) who contribute to the design, conduct, and reporting of research and educational activities funded by the US federal government.
Sec. 2 Purpose
This procedure describes the framework through which the Office of Research and Innovation will support UTD researchers to report the funding, scientific activities, appointments, and other resources that support their research activities. The full and complete reporting of research resources – whether those resources are accessed through UTD or another organization – is required by US federal funding agencies. This procedure also serves to help UTD researchers to identify and mitigate conflicts that appear to bias or unduly influence their ability to perform federally funded research at UTD
Sec. 3 Researcher Responsibilities
Reporting to Funding Agencies: Funded researchers must provide a full and complete report of their research funding, scientific activities, appointments, and other resources when these documents are required by a funding sponsor.
Please visit the Sponsored Projects web page for information and guidelines on the specific funding agency guidelines. The deadline for these documents will vary based on sponsor. This information is subject to change so we recommend reviewing the reporting requirements for your specific grant award.
Reporting to UTD: Funded researchers must report to UTD their external research funding, scientific appointments, in-kind contributions, and other financial relationships related to their research activities. When these activities are reported to UTD, the Conflict of Interest Office will evaluate the relationship with the researcher for conflicts of interest or commitment that must be managed or removed to ensure the researcher does not appear to be biased or unduly influenced by the relationship.
Avoiding Substantial Conflicts: UTD researchers cannot accept or benefit from research resources that are in conflict with their obligations to UTD, or with the commitments they make to their US federal funding agencies. Researchers must have a management plan implemented under UTD Conflict of Interest policy before accepting or benefitting from external research funding and other resources that create an apparent conflict of interest or commitment.
Resolving Potential Conflicts: When a potential conflict is identified, researchers must be responsive to requests for information from the Conflict of Interest Office and work proactively with COI Office to resolve all policy and grant compliance concerns.
Sec. 4 Research Office Responsibilities
Coordinate Funding Agency Reports: The Research office will identify new and continuing awards and funding agreements that include resource reporting requirements, and collect biographical information and research support documents from funded researchers. The Research office will provide guidance and forms for researchers to report their research resources to UTD and funding agencies, and will ensure those guidance and forms are updated to meet funding agency requirements.
Identify Unreported Relationships and Resources: The Research office will screen for potentially undisclosed relationships in public records such as publications and funding announcements. Screening will primarily occur at the award of new federal funding. Other situations that involve screening include monitoring of managed conflicts of interest, evaluating new visitors and collaborations, and inquiries into reports of noncompliance.
Assist Researchers to Identify Reportable Relationships and Conflicts of Interest. The Research office will report possible undisclosed relationships to the researcher and ask for more information. The goal is to understand the nature of the relationship and decide whether reporting of the relationship is needed. The Research office will also evaluate the relationship with the researcher to identify possible conflicts or grant obligations that need to be addressed.
Assist Researchers in Reporting Relationships. The Research office will assist the researcher in reporting the relationship to UTD and funding agencies, as necessary.
Conduct Noncompliance Investigations. The Research office will conduct investigations into undisclosed relationships that appear to involve a substantial instance of noncompliance. Such investigations will be undertaken with oversight by the University Research Integrity Committee and the appropriate school dean.
Respond to Information Requests. The Research office will respond to requests for information from funding agencies, and other freedom of information requests, in keeping with our obligations as a state agency and public research institution.
Sec. 5 Incidents of Noncompliance
Relationships and resources that were not properly reported by a researcher to UTD and their funding agency will be evaluated for possible conflicts of interest or commitment, or other policy or grant compliance issues. The failure to report a financial interest or relationship as required by UTD or funding agency policies is considered noncompliance, but the failure to report does not necessarily affect the performance of a funded project. Insubstantial and substantial noncompliance can be understood as the following:
- Insubstantial incident: situations in which an undisclosed relationship does not appear to bias or interfere with the researcher’s ability to perform funded research activities, or comply with UTD policies, or will be resolved through reporting to UTD and funding agency as necessary.
- Substantial incident: situations in which an undisclosed relationship appears to bias or interfere with the researcher’s ability to perform funded research activities, or comply with UTD policies, including the following:
- There is a substantial conflict as defined by UTD COIC policy
- The failure to report biases or interferes with funded activities
- The undisclosed activity would not have been allowed if disclosed properly
- Multiple incidents of noncompliance for the same funded activity
Investigations into possible incidents of noncompliance may involve collection of information from the following sources:
- Public records of the researcher’s activities and relationships (publications, patent filings, press releases)
- Nonpublic university records
- Interviews and written testimony from the researcher, co-investigators, students and other collaborators
- Records from a related external organization
Possible incidents of substantial noncompliance will be reported the University Research Integrity Committee, and the investigation will be performed by the Conflict of Interest Office under the oversight of the URIC. Determinations of substantial noncompliance may be appealed by the researcher to the full URIC.
Sec. 6 Examples of Conflicts of Interest or Commitment
Examples of apparent conflicts of interest or commitment related to external research funding and resources include the following, especially when these activities are undertaken without required sponsor approval:
- Withholding information from UTD and/or federal sponsors about your research resources
- Assigning intellectual property rights to another organization
- Performing key aspects of your funded research program at another organization
- Transferring nonpublic research data or intellectual property to another organization
- Sharing confidential proposal or award information with another organization
- Involving conflicted visitors in your funded research
- Accepting foreign government talent program funding
Sec. 7 Institutional Oversight
This procedure is implemented by the Office of Research Integrity and Outreach and the Office of Sponsored Projects under the oversight of the University Research Integrity Committee.
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