Frequently Asked Questions

COI Disclosures: Annual and Interim
1. Who needs to complete a disclosure?
  University policy requires that Scholars complete a disclosures annually and to update their disclosure is their outside activities and/or interests change substantially. Scholars are defined as:
  
  • Faculty Fellows: individuals holding research positions that are not tenure-eligible, under University Policy No. 327.
  
  • Faculty Members: includes all faculty members with tenure and tenure-track appointments, as well as benefits-eligible non-tenured or non-tenure track faculty members with the rank of Lecturer or above, under University Policy No. 201.
  
  • Investigators: any university employee who is a Principal Investigator or co-investigator on a research project. This broader term includes all Rice professors of the practice, certain research faculty, and any individual to whom Principal Investigator or co-principal investigator status has been provided. It may also include other individuals, including significant contributors, collaborators, consultants and others regardless of position, title or compensation from an award, who are independently responsible for the development, design, conduct, or reporting of a sponsored research project.
2. What do I need to report in the disclosure?
  Scholars must report immediately and routinely Outside Interests and Activities that are reasonably related to their Institutional Responsibilities. The disclosure corresponds to the prior 12 months period based on calendar year. Scholars must also update their disclosures within 30 days when they take on new Outside Interests or the Interests and Activities they have disclosed previously change substantially. Below are the categories upon which Scholars need to report:
  
  • Remuneration received by the individual, or his or her Family Member, from a publicly traded entity within the twelve months preceding the disclosure and the value of any equity interest in the entity as of the date of disclosure, which, when aggregated, exceeds $5,000. For purposes of this policy, remuneration includes salary and any payment for services not otherwise identified as salary (e.g., consulting fees, honoraria, paid authorship); equity interest includes any stock, stock option, or other ownership interest, as determined through reference to public prices or other reasonable measures of fair market value.
  
  • Remuneration received by the individual, or his or her Family Member, from a non-publicly traded entity in the twelve months preceding the disclosure, which, when aggregated, is in excess of $5,000, or when the person making the disclosure or a Family Member holds any equity interest (e.g., stock, stock option, or other ownership interest) in the entity.
  
  • Intellectual property rights and interests (e.g., patents, copyrights) held by the individual, or his or her Family Member, upon receipt of income related to such rights and interests.
  
  • Income received by the Scholars or his or her Family Member of more than $5,000 from royalties on any single item from any non-Rice activity, including any income from intellectual property rights and interests not jointly owned by the University (such as patents, copyright, and licensing fees).
  
  • Gifts larger than $2,500 any outside (non-Rice) entity.
  
  • Reimbursed or sponsored travel (i.e., that which is paid on behalf of, and not reimbursed to, the individual so that the exact monetary value may not be readily available) that reasonably appear to be related to their Institutional Responsibilities and received from domestic or foreign for-profit (e.g., industry) or nonprofit entities not excluded below (e.g., foundations) if the amount exceeds $5,000 per trip. Disclosure information would include the purpose of the trip, the identity of the sponsor/organizer, the destination, and the duration.
  
  • With regard to travel, Scholars do not need to disclose: a) direct reimbursement or income from seminars, lectures, or teaching engagements sponsored by a federal, state, or local government agency; a U.S. institution of higher education; an academic teaching hospital; a medical center; or a research institute that is affiliated with an institution of higher education; b) income from service on advisory committees or review panels for a federal, state, or local government agency; or c) income from service on advisory committees or review panels for a federal, state, or local government agency, or for a U.S. institution of higher education.
  
  • Special Requirement for PHS Investigators: While the normal requirement is for Scholars to disclose sponsored travel and travel reimbursements annually, PHS Investigators must, within 30 days of receipt (rather than annually), and regardless of the amount, disclose any sponsored travel or reimbursement paid on their behalf by entities required to be disclosed in the travel and travel reimbursement disclosure requirement, as noted above. If upon evaluation the Office of Research Compliance (ORC) feels that additional information is needed to determine whether the sponsored travel or travel reimbursement indicates a Significant Financial Interest, then additional information such as the estimated or actual cost of the travel may be requested.
3. How and to whom do I submit my disclosure?
  Submit disclosures through coi.rice.edu. Once you click on the link, you will be asked to login to the system with your net id and password. You will then be guided through the process to submit your disclosure. Once you submit your disclosure, you will not be able to change the information submitted unless you contact your dean's office and request that the disclosure be reopened. Updates to disclosures may be made at any time during the year.
4. When is the deadline to submit my disclosure?
  You will receive an e-mail notification from the Office of the Provost in mid December alerting you that it is time to complete your annual disclosure. The system will remain open until February. Periodic reminders will be sent.
5. What happens after I submit my disclosure?
  The system will send you an email that your disclosure has been submitted successfully. Once you submit your disclosure the system is locked and you will no longer be allowed to edit your annual disclosure further.
  
  The disclosure will be reviewed by your Dean or his/her designee who will acknowledge receipt of your disclosure and may request information or clarification. The Office of Sponsored Projects and Research Compliance (SPARC) also acknowledges the Dean's determination, or may ask the Faculty Conflicts Committee (FCC) to review the Dean's determination.
  
  If your disclosure indentifies a potential or actual COI, the Dean or his or her designee will request additional information from you to assess the situation. The Dean's office will work with you to draft a suitable management and monitoring plan which will be presented to the FCC for consideration.
  
  The FCC will make a recommendation to either approve the management and monitoring plan or to eliminate the conflict. The final recommendation of the FCC will be sent to the Provost for approval.
6. I do not have any sponsored research at Rice. Do I need to submit a COI disclosure?
  Yes. University Policy requires all Faculty Members, Faculty Fellows, and Investigators (as those terms are defined in Policy 216--see the first FAQ in this section, above) to submit COI disclosures.
7. What happens if I do not submit a disclosure?
  Those who do not submit disclosures as required or do not to file updates when appropriate will have his or her ability to apply for or expend any sponsored research funds suspended until such time as the Faculty Conflicts Committee determines that the conflict has either deemed to be sufficiently managed or has been eliminated.
  
  The suspension of funds may affect other employees or graduate students who are normally paid from those sources.
8. How do I update my COI disclosure?
  Contact conflicts@rice.edu to update your COI disclosure.
  
  Rice is required to report any new COIs for Public Health Service or other Federal funding agency in a timely fashion. Any conflicting interest(s) must be managed, reduced, or eliminated, at least on an interim basis, within sixty (60) days of that disclosure or prior to the expenditure of funds for a new award.
9. I have been asked to give a paid presentation and participate in a review of a non-profit research institution. Do I need to report the income I receive from these activities?
  Maybe. Honoraria and travel reimbursements for this sort of activity that are paid by non-profit or non-governmental entities might be excluded for reporting on the disclosure form but any income from a for-profit entity must be reported. Income from a for-profit entity’s affiliated non-profit entity must be reported.
10. The status of my Outside Interests and Activities has not changed since I submitted a disclosure last year. Do I still need to submit a disclosure for the current year?
  Yes. University policy requires all Scholars to submit disclosures at least annually.
  
  Since many relationships last for several years, the online system saves information submitted in your prior year and allows you to update information as needed.
11. I am on leave from the University/on sabbatical/out of the country. Do I still need to submit a disclosure?
  Yes. So long as you meet the definition of a Faculty Member, Faculty Fellow, or Investigator, you must submit a disclosure annually and update your disclosure as necessary.
Definitions and General Concepts
1. What is a Conflict of Interest (COI)?
  A COI is a situation in which a Scholar may be influenced by considerations of personal gain due to an existing or potential Outside Interest or Activity. Such relationships may affect or might reasonably appear to affect his or her ability to make objective independent judgment in the pursuit of research results, scholarship, or creative work.
  
  The purpose of all COI requirements is to preserve research objectivity and scientific integrity from being corrupted by personal gain and to protect human subjects.
2. What are Institutional Responsibilities?
  Institutional Responsibilities are the professional responsibilities of a Scholar on behalf of the University. Institutional Responsibilities include, for example, activities such as teaching, preparing coursework, counseling students, service on departmental and University-wide committees, research, publishing scholarly work, and other work relevant to his or her academic field of endeavor, professional practice, and consultation.
3. What are Outside Activities?
  Outside Activities include leadership participation in professional, community, or charitable activities; self-employment; participation in business partnerships; or employment or consulting arrangements with Outside Entities. An Outside Activity may be either compensated or uncompensated. In general, any service on any board (for-profit, non-profit, advisory, honorary, or otherwise) will constitute an Outside Activity.
  Outside Activities that appear reasonably related to Institutional Responsibilities must be disclosed through this online system no less frequently than annually.
4. What are Outside Interests?
  Outside Interests include participation in activities for which a financial incentive can be identified such as: income from a job; honoraria; consulting engagements; receipt of advisory board fees; membership; remuneration; gifts or "in kind" compensation; direct payment or reimbursement of travel expenses, (other than those paid for by the University) paid for participation in scholarly and academic endeavors; paid authorships; equity such as stock, stock options or other ownership interests, including equity in start-up companies; non-university grants; non-university contracts; non-university licensing agreements; inventors' shares; and a board or other position in the private sector including non-governmental organizations (NGOs) with advisory or fiduciary duties, even if uncompensated.
  
  Federal COI and University policy stipulate that Outside Interests related to the Scholar's Institutional Responsibilities be reported annually and as the affect the Scholar's ability to conduct their institutional responsibilities effectively.
5. What is a Significant Financial Interest (SFI)?
  An SFI is a financial interest having a significant monetary value (whether that value can be easily determined or not) that belongs to the Scholar or the Scholar’s Family Members, and that reasonably appears to be related to the Scholar’s Institutional Responsibilities, as discussed in the Policy 216 subsection titled “Outside Interests and Activities That Must Be Disclosed.”
  
  An SFI may be is present when the Scholar's receipt of income or participation in an activity has the potential jeopardize the objectivity of the scholar's research and scholarly endeavors. It is incumbent upon the Scholar to disclose any relationships or income that might be perceived as creating incentives whereby the credibility of the integrity of their work for Rice might, or might appear to be, compromised. Scholars are encouraged to discuss any situations that might present a SFI with their dean or with the staff in the Office of Sponsored Projects and Research Compliance.
6. What are some examples of Outside Interests or Activities that appear reasonably related to a Scholar's Institutional Responsibilities?
  Below are examples of Outside Interests that appear reasonably related to an individual’s Institutional Responsibilities. While not all of them present either a COI, all of them need to be disclosed for review:
  
  • The wife of a Faculty Member in Rice’s Computer Science department is a full-time employee of the Microsoft Corporation. The Faculty Member has a sponsored research agreement with Microsoft and routinely receives gifts from Microsoft for his research at Rice.
  
  • A Faculty Member holds $10,000 worth of stock in Yamaha Corporation, producers of pianos and other instruments. The Faculty Member teaches piano at the Shepherd School.
  
  • An oil and gas company reimburses the travel expenses of an Investigator’s trip to seven out-of-state conferences a year. The last two were in Hawaii. The Investigator’s research involves the environmental impact of natural gas extraction.
  
  • A Faculty Member in the Art History department has a written a survey textbook for the introduction to Art History. The textbook is used by her class and throughout the country. She receives $15,000 in royalties annually.
7. What are some examples of Outside Interests and Activities that might need to be eliminated?
  While not exhaustive, here are some examples of activities that would likely interfere with a Scholar's ability to fulfill his/her Institutional Responsibilities. As such, participation in these activities may result in a recommendation that the Scholar eliminate the Outside Interest or Activity.
  
  • Directing the purchase of equipment, instruments, materials, services, or other items from an Outside Entity in which the person making the disclosure or a Family Member has a significant or controlling interest;
  
  • Transmitting to an Outside Entity sponsored research products, results, materials, records, or information not available to the public. (This does not preclude appropriate consulting on the basis of sponsored research results where there are no conflicting relationships);
  
  • Using for personal gain (or other unauthorized purposes) privileged information acquired in connection with sponsored research or other University activities;
  
  • Accepting gratuities or special favors from an Outside Entity with which the University does (or may do) business;
  
  • Being simultaneously involved in activities of Outside Entities and activities within Rice that are competing directly for government and/or private funds;
  
  • Making an academic or administrative decision that could result in their personal gain;
  
  • Simultaneously receiving outside remuneration and university remuneration for the same services or activities; and
  
  • Involving students and staff, over whom they exercise supervisory or academic responsibility at the University, in their Outside Activities.
8. What are some examples of situations that create COIs resulting from a SFI?
  These examples are of situations which likely present manageable and an unmanageable COIs:
  
  a) An Investigator uses his laboratory at Rice to do product-testing research, paid for by a company in which he is a 20% owner and founder, which seeks to validate advertising claims made about a product sold by that company.
  
  b) An employee directs the purchase of supplies for the University toward a business in which he or his immediate family has an SFI.
  
  c) A Faculty Member acts as the thesis or dissertation advisor to a graduate student for a research project, suggested by the Faculty Member, that the Faculty Member expects to substantially enhance the value of a company in which the faculty member has a significant interest.
9. What are some examples of situations that create COIs but are probably manageable with a management and monitoring plan?
  These examples are probably manageable with a management and monitoring plan:
  
  a) An Investigator conducts federally- or foundation-sponsored non-clinical research on a product developed by a company for which he is a consultant.
  
  b) An Investigator who is a member of a company's scientific advisory board conducts non-clinical research sponsored by that company.
  
  c) An Scholar manages a design and construction project involving an architectural firm in which his spouse is a partner, when the Scholar did not participate in the selection of the firm for the project.
  
  d) An Investigator conducts federally- or foundation-sponsored basic research on a University invention that has been licensed to a company for which he consults, and on which he receives a share of University royalties
10. Which Outside Interests need to be reported to the University?
  Scholars must, at a minimum, disclose to the University the following Outside Interests and relationships outlined below that reasonably appear to be related to their Institutional Responsibilities:
  
  • Remuneration received by the individual, or his or her Family Member, from a publicly traded entity within the twelve months preceding the disclosure and the value of any equity interest in the entity as of the date of disclosure, which, when aggregated, exceeds $5,000. For purposes of this policy, remuneration includes salary and any payment for services not otherwise identified as salary (e.g., consulting fees, honoraria, paid authorship); equity interest includes any stock, stock option, or other ownership interest, as determined through reference to public prices or other reasonable measures of fair market value.
  
  •Remuneration received by the individual, or his or her Family Member, from a non-publicly traded entity in the twelve months preceding the disclosure, which, when aggregated, is in excess of $5,000, or when the person making the disclosure or a Family Member holds any equity interest (e.g., stock, stock option, or other ownership interest) in the entity.
  
  •Intellectual property rights and interests (e.g., patents, copyrights) held by the individual, or his or her Family Member, upon receipt of income related to such rights and interests.
  
  •Income received by the Scholars or his or her Family Member of more than $5,000 from royalties on any single item from any non-Rice activity, including any income from intellectual property rights and interests not jointly owned by the University (such as patents, copyright, and licensing fees).
  
  •Gifts larger than $2,500 any outside (non-Rice) entity.
  
  •Reimbursed or sponsored travel (i.e., that which is paid on behalf of, and not reimbursed to, the individual so that the exact monetary value may not be readily available) that reasonably appear to be related to their Institutional Responsibilities and received from domestic or foreign for-profit (e.g., industry) or nonprofit entities not excluded below (e.g., foundations) if the amount exceeds $5,000 per trip. Disclosure information would include the purpose of the trip, the identity of the sponsor/organizer, the destination, and the duration.
  
  •With regard to travel, Scholars do not need to disclose: a) direct reimbursement or income from seminars, lectures, or teaching engagements sponsored by a federal, state, or local government agency; a U.S. institution of higher education; an academic teaching hospital; a medical center; or a research institute that is affiliated with an institution of higher education; b) income from service on advisory committees or review panels for a federal, state, or local government agency; or c) income from service on advisory committees or review panels for a federal, state, or local government agency, or for a U.S. institution of higher education.
  
  •Special Requirement for PHS Investigators: While the normal requirement is for Scholars to disclose sponsored travel and travel reimbursements annually, PHS Investigators must, within 30 days of receipt (rather than annually), and regardless of the amount, disclose any sponsored travel or reimbursement paid on their behalf by entities required to be disclosed in the travel and travel reimbursement disclosure requirement, as noted above. If upon evaluation the Office of Research Compliance (ORC) feels that additional information is needed to determine whether the sponsored travel or travel reimbursement indicates a Significant Financial Interest, then additional information such as the estimated or actual cost of the travel may be requested.
11. Which Outside Interests do not need to be disclosed to the University?
  The following forms of remuneration do not ordinarily need to be reported by Scholars:
  
  •Salary, royalties, or other remuneration by the University if the Scholar or Family Member is currently employed or otherwise appointed by the University.
  
  •Intellectual property rights assigned to the University and agreements to share in royalties related to such rights.
  
  •Income from investment vehicles, such as mutual funds and retirement accounts, as long as the Scholar does not directly control the investment decisions made by these vehicles.
  
  •Outside Interests that are not related at all to the Scholar's Institutional Responsibilities.
12. What is role of the Faculty Committee on Conflicts (FCC)?
  The role of the FCC is to review, revise as needed, and recommend for approval management of any COI identified. The FCC also has responsibility for monitoring management plans. The FCC is a committee composed of Faculty Members and staff, and chaired by the Vice Provost for Research (or his or her designee).
13. Who are considered Faculty Members, Faculty Fellows, and Investigators (a.k.a. Scholars)?
  Policy 216 defines these individuals, referred to collectively as Scholars, as the following:
  
  • Faculty Members: all faculty with tenure and tenure track appointments under University Policy No. 201, as well as faculty fellows and benefits-eligible non-tenured or non-tenure track faculty with the rank of Lecturer or above.
  
  • Faculty Fellows: individuals holding benefits-eligible research positions that are not tenure-eligible. These individuals include Research Faculty, senior Research Faculty, and distinguished Research Faculty and Faculty Fellows. See University Policy No. 327 for further guidance.
  
  • Investigators: any university employee who is a principal investigator or co-investigator on a research project. This broader term includes all Rice professors of the practice, certain research faculty, and any individual to whom principal investigator or co-principal investigator status has been provided. It may also include other individuals, including significant contributors, collaborators, consultants and others regardless of position, title or compensation from an award, who are independently responsible for the development, design, conduct, or reporting of a sponsored research project.
14. Who is considered a Family Member?
  Under Rice Policy 216, a "Family Member" is defined as the Scholar’s spouse, domestic partner, or dependents with financial interests related to the Scholar’s Institutional Responsibilities.
  
  However, since the integrity of the research and scholarship of Scholars is vital to the mission of the University, Scholars should also be sensitive to situations where other family members such as a parent, sibling, or non-dependent children may have a Significant Financial Interest reasonably related to the Scholar’s Institutional Responsibilities (such as a significant investment in a start-up company that has licensed the Scholar’s intellectual property). In such cases, to avoid the appearance of a financial COI, it may be prudent for the Scholar to disclose such additional interests of which he or she is aware.
15. What University policies apply to COI?
  • Policy 216, Management of the Research and Other Outside Interests (COI policy for Scholars)
  • Policy 832, Conflict of Interest (COI policy for all University employees)
  • Policy No. 201, Faculty Appointments, Promotions, and Tenure
  • Policy No. 307, Issuing and Monitoring Subawards and Subcontracts
  • Policy No. 327, Research Faculty
  • Policy 411, Discipline
  • Policy No. 831-96, Personal Use of University Property
Management and Monitoring
1. Will the content of my COI disclosures be kept confidential?
  Persons to whom COI disclosures are made, who participate in the review process, or who have access to information from the disclosures shall take reasonable steps to ensure that the confidentiality of the information in the disclosure is maintained. The information received shall be handled confidentially unless disclosure is part of the management plan, is required by law, University policy or procedure, or is warranted to address a violation of this or other University policies.
2. What happens if I report an Outside Interest or Activity?
  If you report an Outside Interest or Activity, your Dean (or his or her designee) may contact you for additional information. In cases where actual or potential COIs are identified, your Dean will work with you to develop a management and monitoring plan. After receiving a recommendation from the Dean, the FCC will recommend to the Provost whether the conflict is manageable or should be eliminated.
3. What is a management and monitoring plan?
  A management and monitoring plan provides steps to be taken to manage COI. Examples of conditions or restrictions that may be imposed include but are not limited to:
  • Public disclosure of the conflict of interest;
  • For research programs involving human subjects research, disclosure of financial conflicts of interest directly to participants;
  • Monitoring of research by independent reviewers;
  • Modification of the research plan;
  • Disqualification from participation in the portion of funded research that could be affected by the conflict of interest;
  • Mandated graduate student and post-doctoral training in their roles and rights in research;
  • Reduction or elimination of the Outside Interest (e.g., sale of an equity interest); and/or
  • Severance of relationships that create conflicts.
4. What is the role of my Dean's office in the identification and resolution of COI?
  The Dean’s office has the following responsibilities:
  
  • Preliminary review of submitted disclosures, requesting additional information as needed;
  • Coordination with Scholars to draft a management and monitoring plan that ensure compliance with all University and granting agency COI policies;
  • Coordination with the Office of Sponsored Projects and Research Compliance in the identification and management of COIs;
  • Ensure the on-going adherence to the Scholar's Management and Monitoring Plan after it has been reviewed by the Faculty Conflict Committee (FCC) and approved by the Provost; and
  • Ensure that appropriate disclosures and certifications are submitted with all sponsored research proposals and updated as TBN staff are added.
5. What is the role of the Office of Sponsored Projects and Research Compliance (SPARC) in the identification of any disclosed Conflicts of Interest?
  SPARC has the following responsibilities:
  
  • Expert level interpretation of University policy and federal regulations on COI;
  • Maintaining standard operating procedures related to implementation of COI policies;
  • Ensuring that the Rice COI system is functioning properly and that annual disclosures are distributed timely;
  • Reviewing disclosures independently from the deans to ensure objectivity in the COI review and monitoring process, as Rice’s institutional official required under PHS and regulations at 42 CFR Part 50;
  • Notifying deans’ offices of COIs that may need to be addressed;
  • Assisting in the coordination of the development of management and monitoring plans;
  • Ensuring that an annual review takes place for each approved management and monitoring plan;
  • Ensuring that retrospective reviews take place for COIs not disclosed timely;
  • Convening FCC meetings, recording FCC meeting minutes, and distributing and collecting meeting materials;
  • Coordinating with the Office of the Provost for final signature;
  • Ensuring that the any sponsoring agencies are appropriately notified of the management of COI;
  • Providing within (5) business days, upon request, information about disclosed and managed COI; and
  • Monitoring of compliance with University policies and procedures and management plans.
Proposal and Award Disclosures
1. What are my obligations at the proposal submission stage:
  University Policy 216 requires all Rice Scholars to submit updated disclosures of relevant financial interests and activities at the time at which they submit sponsored research proposals.
  
  Investigators must answer the following question in the Conflict of Interest section on Cayuse:
  
  Have any of this project’s Investigators reported a financial interest or activity that reasonably appears to be related to the design, conduct, or reporting of the research to be conducted if this proposal is funded?
2. Will the Office of Sponsored Projects and Research Compliance (SPARC) still process my proposal if I report Outside Interests and Activities?
  Yes. However, if a COI is present, no funds can be established nor any funds spent on continuing awards until a management and monitoring plan is in place.
3. Are subcontractors required to complete a disclosure?
  Yes. According to the Public Health Service:
  The regulations are aimed at ensuring that the design, conduct, or reporting of research funded under grants and cooperative agreements will not be biased by any conflicting financial interest of the Investigators responsible for the research are applicable to each Institution that applies for NIH grants or cooperative agreements for research or to each Institution that submits a proposal for a research contract whether in response to a solicitation or otherwise and, through the implementation of the regulation by each Institution, to each Investigator participating in such research.
  
  Accordingly, Institutions carrying out NIH-funded research through sub-recipients (e.g., contractors, collaborators) or subcontractors must take reasonable steps to ensure that Investigators working for such entities comply with the regulation, either by requiring the Investigators to comply with the awardee Institution's policy or by requiring the entities to provide appropriate assurances to the awardee Institution. Sub-recipients/subcontractors must report identified FCOIs to the awardee Institution; the awardee Institution must report to the NIH the existence of any conflicting interests arising from sub-recipients/subcontractors and assure that the interest has been managed, reduced, or eliminated in accordance with the regulation.
4. Are disclosures required for an individual with no effort and/or requested salary?
  Potentially. PIs and Investigators must submit disclosures if they can influence the design, conduct, or reporting of research proposed or funded, even if the they have no committed effort or no remuneration is being requested for their effort on the project. As a suggestion, such disclosures or certifications should be provided for any person named in the modular or detailed budget justifications, and/or whose biographical sketch is included in the application.
5. Do the disclosure requirements extend to graduate students working on sponsored research?
  Potentially. If, through his or her work on the research project, the graduate student falls under the definition of Investigator, he or she must submit a disclosure and otherwise comply with applicable regulations.
6. When does a disclosure or certification have to be provided for a person hired to fill a “to be named” personnel slot?
  As a “best practice,” when the position is filled and an individual is hired, that individual should complete a Rice University disclosure.
7. Is a disclosure required for a post-doc receiving a fellowship like the NRSA?
  Yes. Because these fellowships are intended to support the mentored research project designed by the fellows, their role in the research meets the definition of Investigator.
8. Does this policy apply to training grants? Do I need to provide the forms for all of the mentors even if they do not have any specified effort on the grant?
  Yes. A good rule of thumb is to provide a disclosure or certification for any individual whose biographical sketch is included in the proposal.
9. Will the same procedures be followed for all sponsored research?
  Yes. Disclosures should be submitted for investigators on all awards, federal or non-federal.
10. Do these requirements extend to pre-award or advance spending fund?
  Yes. Please note that if the Investigator has reported a COI that requires a management plan, funds cannot be established until the COI has been satisfactorily resolved and a management and monitoring plan is in place. COIs must be resolved within 60 days of receipt of a notice of award.
11. Do Scholars (Investigators) at other institutions need to use our COI forms or can they use their own proposal specific COI disclosure form?
  Rice may accept either. If an Outside Interest or Activity of an external Investigator is identified, the Office of Sponsored Projects and Research Compliance (SPARC) will contact the external Investigator’s research administration unit requesting documentation that either the Outside Interest or Activity posed no COI or that a financial COI has been managed, reduced, or eliminated. If the external institution or Investigator does not have a review process, Rice’s FCC will review the relationship.
12. Can a fund be set up if a COI is identified?
  No. Before a fund can be established, the University must report to the appropriate funding agency the existence of a conflicting interest and confirm that the interest has been managed, reduced or eliminated and that the Investigator has consented to the proposed management plan.
13. What are the responsibilities of a PI for reporting new or significantly changed Outside Interests and Activities during the period of the project?
  PIs have a responsibility on an ongoing basis during the tenure of the award to report any new Outside Interests and Outside Activities by updating their COI disclosures. If a COI is identified, a plan to manage, reduce, or eliminate the COI must be developed and agreed upon by the Investigator and reported to the funding agency.
Requirements for Public Health Service (including NIH) Investigators
1. I have funding from the PHS (NIH). Is there anything special I need to know?
  Yes. The regulations provide specific requirements for these Investigators and the University in the following areas:
  • Reporting sponsored travel and travel reimbursements;
  • Investigator COI training;
  • University reporting to PHS (NIH) should an actual or potential COI be disclosed;
  • Reporting, within five business days of a request from the public, of SFIs held by senior/key personnel in a PHS project that the University deems to be COIs.
  
  Read the FAQs below for more information in each area.
2. What kinds of sponsored travel and travel reimbursements do I have to report?
  While the normal requirement is for Scholars to disclose sponsored travel and travel reimbursements annually, PHS Investigators must, within 30 days of receipt (rather than annually), and regardless of the amount, disclose any sponsored travel or reimbursement paid on their behalf.
  
  However, like all other Scholars, PHS Investigators do not need to disclose: a) direct reimbursement or income from seminars, lectures, or teaching engagements sponsored by a federal, state, or local government agency; a U.S. institution of higher education; an academic teaching hospital; a medical center; or a research institute that is affiliated with an institution of higher education; b) income from service on advisory committees or review panels for a federal, state, or local government agency; or c) income from service on advisory committees or review panels for a federal, state, or local government agency, or for a U.S. institution of higher education.
  
  The following information must be reported:
  • purpose of the trip;
  • the identity of the sponsor/organizer;
  • the destination; and
  • the duration.
3. What kind of COI training am I required to complete?
  All PHS-funded Investigators must certify that they have viewed 2 sets of COI training slides: (1) PHS regulation-specific slides and (2) slides about Rice’s policies and procedures. Training must be completed at least once every four years.
4. What are the PHS reporting requirements should an actual or potential COI be identified?
  Should an actual or potential COI be identified, Rice will submit initial, annual (i.e., ongoing), or revised FCOI reports to the NIH:
  
  • Prior to the expenditure of funds;
  • Within 60 days of identification of a COI for an Investigator who is newly participating in the project;
  • Within 60 days for new, or newly identified, COIs for existing Investigators;
  • At least annually to provide the status of the COI and any changes to the management plan, if applicable, until the completion of the project; and
  • Following a retrospective review to update a previously submitted report, if appropriate.
  
  Elements of these reports shall include, but are not necessarily limited to, the following:
  
  • Project number;
  • PD/PI or contact PD/PI if a multiple PD/PI model is used;
  • Name of the Investigator with the COI;
  • Name of the entity with which the Investigator has a COI;
  • Nature of the financial interest (e.g., equity, consulting fee, travel reimbursement, honorarium);
  • Value of the financial interest (dollar ranges are permissible: $0-$4,999, $5,000-$9,999, $10,000-$19,999; amounts between $20,000-$100,000 by increments of $20,000; amounts above $100,000 by increments of $50,000), or statement that the interest is one whose value cannot be readily determined through reference to public prices or other reasonable measures of fair market value;
  • A description of how the financial interest relates to the PHS-funded research and the basis for the University’s determination that that financial interest conflicts with such research;
  • A description of the key elements of the Institution’s management plan, including:
  o Role and principal duties of the conflicted Investigator in the research project;
  o Conditions of the management plan;
  o How the management plan is designed to safeguard objectivity in the research project;
  o Confirmation of the Investigator’s agreement to the management plan;
  o How the management plan will be monitored to ensure Investigator compliance; and
  • Other information as needed.
  
  Annual reports shall also include the following:
  
  • Status of the potential FCOI and Management Plan;
  • Status of FCOI (i.e., whether the FCOI is still being managed or why the FCOI no longer exists); and
  • Changes to the management plan, if any.
  
  Should a potential Outside Interest that was not disclosed timely by the Investigator, for whatever reason, or was not previously reviewed by Rice during an ongoing PHS-funded research project (e.g., was not timely reviewed or reported by the subrecipient) is identified:
  
  • If no bias is found: within 60 days, the FCC will complete a review of the Outside Interest and the ORCT file with the appropriate PHS awarding component an FCOI report, which provides the information stated above. Thereafter, an annual FCOI report shall be filed.
  • If bias is found: FCC shall complete the retrospective review and ORCT will promptly file with the appropriate PHS awarding component an mitigation report, which will include:
  
  o A description of the impact of the bias on the project; and
  o Rice’s plan of action or actions taken to eliminate or mitigate the effect of the bias (e.g., impact on the research project; extent of harm done, including any qualitative and quantitative data to support any actual or future harm; analysis of whether the research project is salvageable).
  
  When reports to the PHS funding components are filed, the PI will be notified in advance.
5. Under what circumstances will Rice disclose information about my COIs to the public?
  Prior to the University’s expenditure of funds under a PHS-funded research project, the University will respond to requests for information within 5 business days of the request concerning certain outside interests held by Senior/Key Personnel and disclosed. These public disclosures are required by federal regulation.
  
  The Outside Interests must meet the following criteria in order to be disclosed:
  • The Outside Interest was disclosed and is still held by the Senior/Key Personnel;
  • Rice determines that the Outside Interest is related to the PHS-funded research; and
  • Rice determines that the Outside Interest is a COI.
  
  “Senior/Key Personnel” is defined as the PD/PI and any other person identified as senior/key personnel the University in the grant application, progress report, or any other report submitted to the PHS by the University.
  
  As required under the regulations, the University shall respond to such requests dated no later than three years from the date the information was most recently updated. When Rice responds to such requests, the University will notify the PI in advance.
6. What kind of information will Rice disclose for these requests?
  The response shall include, at minimum:
  
  • The Investigator’s name;
  • The Investigator’s title and role with respect to the research project;
  • The name of the entity in which the SFI is held;
  • The nature of the SFI; and
  • The approximate dollar value of the financial interest (dollar ranges are permissible: $0-$4,999, $5,000-$9,999, $10,000-$19,999; amounts between $20,000-$100,000 by increments of $20,000; amounts above $100,000 by increments of $50,000), or statement that the interest is one whose value cannot be readily determined through reference to public prices or other reasonable measures of fair market value.
Sponsored Travel Disclosures
1. Do I need to report all sponsored travel or just sponsored travel related to my Institutional Responsibilities?
  All sponsored travel paid by for profit entities which appears reasonably related to your Institutional Responsibilities must be disclosed. For PHS Investigators, all travel must be disclosed, as required by federal regulations, regardless of the amount; however, travel paid by any of the entities described in the paragraph below are not required to be disclosed. For all other Research Faculty, Faculty Fellows, and Investigators, only travel related to one's Institutional Responsibilities must be reported if the amount exceeds $5,000 per trip, unless any of the exceptions below apply.
  
  You do not need to disclose: a) direct reimbursement or income from seminars, lectures, or teaching engagements sponsored by a federal, state, or local government agency; a U.S. institution of higher education; an academic teaching hospital; a medical center; or a research institute that is affiliated with an institution of higher education; b) income from service on advisory committees or review panels for a federal, state, or local government agency; or c) income from service on advisory committees or review panels for a federal, state, or local government agency, or for a U.S. institution of higher education.
2. What are some examples of reimbursements I am required to disclose?
  Here are two types of reimbursements you are required to disclose:
  
  1. A third party (e.g., a corporation) directly pays in whole or in part for travel on your behalf.
  
  2. You pay for travel and third party reimburses your travel expenses.
3. I'm an Investigator for a research project sponsored by a corporation, and those funds will be reimbursing my travel to a conference related to the project. Do I have to disclose those reimbursements?
  No. If the funds are routed through a University account (say, an R-fund), even if a corporation initially provided these funds, such reimbursements are not subject to the disclosure requirements. NIH has clarified that these types of situations, the University is already aware of the payment; as such, no disclosure is required.
4. Do I need to report reimbursement of travel from another University?
  It depends. A Scholar would need to report any sponsored travel from a U.S. university if the source of funding for the travel was provide by a foundation or for profit entity.

Conflict of Interest

Frequently Asked Questions

COI Disclosures: Annual and Interim

Definitions and General Concepts

Management and Monitoring

Proposal and Award Disclosures

Requirements for Public Health Service (including NIH) Investigators

Sponsored Travel Disclosures