Requirements by Role
UTD employees, including faculty and staff researchers, must disclose academic appointments, consulting and professional activities, board service, and financial interests that create the appearance for conflict of interest to comply with UTDPP1102. Approval by the employee’s department and/or school dean is required prior to engaging in activities that require commitment of time and effort.
UTD researchers must submit a Conflict of Interest Disclosure (“CID”) on an annual basis to comply with the requirements of the UTDPP1029. The CID must identify research projects and other Institutional Responsibilities at risk for the appearance of conflict of interest and commitment. Researchers must submit or have a current CID on file no later than the time of application for external research funding, or at the time of research protocol submission (e.g., submission to the Institutional Review Board).
Graduate students must complete a Conflict of Interest Disclosure (“CID”) on an annual basis if they serve as principal investigator or co-investigator for research that is supported by external funding, serve as principal investigator or co-investigator for research that requires approval by the UTD Institutional Review Board, or engage in other Institutional Responsibilities at risk for the appearance of conflict of interest and commitment. Graduate students in these roles must submit or have a current CID on file no later than the time of application for external research funding, or at the time of research protocol submission (e.g., submission to the Institutional Review Board).
Visitors must complete a Conflict of Interest Disclosure (“CID”) on an annual basis if they serve as an investigator or senior/key personnel for research that is supported by external funding, serve as principal investigator or co-investigator for research that requires approval by the UTD Institutional Review Board, or engage in other Institutional Responsibilities at risk for the appearance of conflict of interest and commitment. Visitors in these roles must submit or have a current CID on file no later than the time of application for external research funding, or at the time of research protocol submission (e.g., submission to the Institutional Review Board).
Disclosing Activities and Interests
Faculty and researchers should submit an Activity and Interest Report (“AIR”) to disclose the nature and extent of outside activities and financial interests in compliance with UTD policy. Researchers must submit an AIR before engaging in a new outside activity or accepting a financial interest that creates the appearance for conflict. Researchers must update their AIR before making material changes to the scope of their outside activity or financial interest in the entity. Researchers need to only complete one AIR for each external entity in which they have an outside activity or financial interest. The AIR allows the researcher to disclose all aspects of their relationship with that entity.
Disclosing Responsibilities at risk for Conflict of Interest or Commitment
Researchers must submit a Conflict of Interest Disclosure (“CID”) on an annual basis to identify funded research projects, intellectual property agreements, human subject research protocols, and other Institutional Responsibilities at risk for the appearance of conflict of interest and commitment. Responsibilities at risk for the appearance of conflict of interest and commitment include:
- Experimental, clinical, or product design
- Data collection, use, and sharing
- Publication or dissemination of the results of research
- Invention disclosure and assignment
- Student and trainee mentoring and supervision
- Facilities access and use
- Contract management
- Faculty committee membership
- Decisions concerning risk to human subjects
- Decisions concerning risk to animal subjects
- Other decisions made on behalf of UTD
Failure to disclose may delay the grant proposal process, as without an active disclosure, funding proposals may not be submitted to or accepted by the funding agency and pending awards may not be processed by the Office of Sponsored Projects. Timely disclosure is of particular importance for researchers with active or proposed projects funded by the National Institutes of Health and National Science Foundation.
Review and Approval
Activity and Interest Reports will be reviewed by the COI Office for compliance with UTD policy and the risk for the appearance of conflict of interest or commitment. After COI review, an AIR that involves an outside activity will be reviewed by the researcher’s Approval Authority. The President has delegated responsibility and authority for the approval of outside activities to the following offices:
- For members of the faculty: Dean
- For deans and department chairs: Provost
- For administrative and professional staff: Supervisor
Note for researchers in the schools of Natural Sciences and Mathematics, and Engineering and Computer Sciences: Activity and Interest Reports that involve an outside activity will also be routed to the reseacher’s department or program head for review.
- UTDPP1101 Outside Activities for Executive and Purchasing Officials – applies to all UTD Executive Officers and employees responsible for procurement and contract management activities.
- UTDPP1102 Outside Activities – applies to all other all UTD employees, including researchers.
- UTDPP1029 Research Conflict of Interest – applies to faculty, staff, and students responsible for the design, conduct, or reporting of research.
- UTDPP1002 Intellectual Property
- UTDPP1110 Institutional Conflicts of Interest
- Uniform Guidance (200.112 and 200.318)
- PHS Federal Regulations (42 CFR Part 50 Subpart F, 45 CFR Part 94)
- National Science Foundation (Proposal and Award Policies and Procedures Guide)
- FAR Organizational and Consultant Conflicts of Interest (Subpart 9.5)
State of Texas Government Code
- Texas Government Code Chapter 572 – Personal Financial Disclosure, Standards of Conduct, and Conflict of Interest.
UT System Regents Rules and Systemwide Policies
- UT System Board of Regents’ Rules and Regulations: 30103 (Standards of Conduct), 30104 (Conflict of Interest), 60306 (Use of University Resources), Series 90000 (Rules for Intellectual Property)
- UT Systemwide Policy 175 (Disclosure of Significant Outside Interests and Management and Reporting of Financial Conflicts of Interest in Research)
- UT Systemwide Policy 180 (Conflicts of Interest, Conflicts of Commitment, and Outside Activities)
Conflict of Interest
A conflict of interest is a situation in which a personal, financial, or organizational interest could directly or significantly affect an individual’s performance of their institutional responsibilities on behalf of UTD, including the design, conduct, or reporting of research. A conflict of interest generally involves questions of financial or personal gain.
Conflict of Commitment
A conflict of commitment is a situation in which the time or effort that an employee devotes to an outside activity directly or significantly interferes with the employee’s fulfillment of their institutional responsibilities on behalf of UTD, or when the employee uses State of Texas property without authority in connection with the employee’s outside activity. A conflict of commitment generally involves questions of time, use of resources, and conflicting obligations.
Institutional Responsibilities are the work an individual performs for UTD as part of his or her appointment or position, including research, intellectual property assignment, data use, professional practice, teaching, mentoring, administrative duties, committee membership, purchasing, and facilities use.
Financial interests held by UTD researchers, in an entity other than UTD, that appear related to the researcher’s Institutional Responsibilities require disclosure under the Research Conflict of Interest policy (UTDPP1029). Such interests include:
- Compensation, travel reimbursement, or royalty income from a single entity that exceeds $5,000 in the previous 12 months.
- An equity interest that represents more than $5,000 in fair market value, more than 10% voting or participating interest, a controlling interest, or any interest (>0%) in a privately held business entity.
- A gift that represents more than $250 in value.
- A fiduciary interest in a business or non-profit entity (i.e., a position entrusted with the protection of the assets of an entity, such an executive, an officer, or director).
A financial interest is related if the interest could be affected by the researcher’s performance of his or her Institutional Responsibilities, or is in an entity whose financial interest could be affected by the responsibility.
Outside Activity is consulting and professional activities, academic appointments, board service, or other compensated activities that occurs outside an individual’s scope of employment for UTD. Approval is required prior to engaging such activities, particularly if the activity creates the appearance for conflict of interest or commitment. Such activities should benefit UTD and/or provide opportunity for professional development. Scholarly and governmental service activities do not require prior approval, but should be reported to department heads at least annually.
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