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Conflict of Interest

What Constitutes a Reportable Significant Financial Interest (SFI) 

Significant Financial Interest is defined as a Financial Interest consisting of one or more of the following interests of the Investigator or the Investigator's Covered Family Members that reasonably appears to be related to the Investigator's Institutional Responsibilities:

  1. Remuneration or Equity Interest in a Publicly Traded Entity: A Financial Interest in which the value of any Remuneration received from the entity in the twelve months preceding the disclosure and the value of any Equity Interest in the entity as of the date of disclosure, when aggregated, exceeds $5,000;
  2. Remuneration or Equity Interest in a Non-Publicly Traded Entity: A Financial Interest in which the value of any Remuneration received from the entity in the twelve months preceding the disclosure, when aggregated, exceeds $5,000, or when the Investigator holds any Equity Interest;
  3. Intellectual Property: Any receipt of income for Intellectual property rights and interests (e.g. patents, copyrights);
  4. Reimbursed or Sponsored Travel: Any reimbursed or sponsored travel in the twelve months preceding the disclosure in which the value (aggregated per entity that reimburses or sponsors the travel) exceeds $5,000. This does not apply to Investigators who do not receive PHS funding;  See "SFI Exclusions" below for additional exclusions for travel that is not reportable.

SFI Exclusions: The term Significant Financial Interest (SFI) does not include the following types of financial interests:

  1. Salary, royalties, or other Remuneration paid by UTA to the Investigator or Covered Family Member if the Investigator or Covered Family Member is currently employed or otherwise appointed by UTA, including Intellectual Property rights assigned to UTA and agreements to share in royalties related to such rights;
  2. Income from investment vehicles, such as mutual funds and retirement accounts, as long as the Investigator or Covered Family Member does not directly control the investment decisions made in these vehicles;
  3. Income from seminars, lectures, or teaching engagements sponsored by a federal, state, or local government agency, an institution of higher education 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;
  4. Income from service on advisory committees or review panels for a federal, state, or local government agency, an institution of higher education 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;
  5. Travel that is reimbursed or sponsored by a federal, state, or local government agency, an institution of higher education 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; and
  6. Travel not meeting the exceptions in part (5) above, but is valued at less than $5,000 per entity that reimburses or sponsors the travel.

COI Disclosure Form 

A new Conflict of Interest Disclosure Form has been developed to comply with the 2011 COI regulations. It is fully electronic and accessible here:https://www.uta.edu/mentis/public/#coi/disclosure/my. Covered Individuals must submit the Disclosure Form at least annually, or within 30 days of discovering or acquiring a new, reportable SFI.

If you face any issues with submitting the COI Disclosure forms please contact the ERA Helpdesk at 817-272-1060 or email us at erahelpdesk@uta.edu.

COI Training 
A new training module has also been developed in response to the COI regulations. Investigators funded by PHS are required to complete the training before engaging in any PHS research, and every four years thereafter. Other Investigators are encouraged to complete this training voluntarily, as it contains some important information and a review of key terms. The training is brief and available electronically at the following link: https://www.uta.edu/ra/real/researchspace.php?view=7.

Resources 

2011 PHS Conflict of Interest Regulations, 42 CFR Part 50, Subpart F 

UT Arlington Policy for Disclosure, Management, and Reporting of Financial Conflicts of Interest in Research (COI Policy)

UT Arlington COI Disclosure Form:  https://www.uta.edu/mentis/public/#coi/disclosure/my

UT Arlington Training: Conflicts of Interest in Research: Disclosure, Management, and Reporting.

NIH Conflict of Interest Page:https://grants.nih.gov/grants/policy/coi/

NIH FAQs: https://grants.nih.gov/grants/policy/coi/coi_faqs.htm

Summary of Major Changes from 1995 to 2011 COI Regulations:http://grants.nih.gov/grants/policy/coi/summary_of_major_changes.doc.

UT Arlington Research Administration, Regulatory Services: 817-272-3723, regulatoryservices@uta.edu 

For Technical Questions regarding the COI Disclosure forms, contact ERA Helpdesk at 817-272-1060 or email us at erahelpdesk@uta.edu.