FAQs - Office of Research Integrity and Compliance

This page contains answers to a few of our frequently asked questions that have quick answers. You may also want to view our Guidance page for more in-depth guidance on topics that require a bit more explaining, or to review the guidelines and reference material available on our Documents and Forms page.

Sponsor-Specific Requirements

Is CMU compliant with the PHS FCOI regulations?

Yes. CMU's policy and processes are compliant with the PHS Financial Conflict of Interest (FCOI) rules and regulation. If you are asked about this by a collaborating institution for one of your research projects, you may direct them to the FDP FCOI Institutional Clearinghouse where our compliance is documented. Questions may also be directed to coi-compliance@andrew.cmu.edu .

Is CMU compliant with the DOE Interim COI policy?

Yes. CMU's policy and processes are compliant with the DOE Interim COI Policy [PDF]. If you are asked about this by a collaborating institution for one of your research projects, you may direct them to this FAQ. Questions may also be directed to coi-compliance@andrew.cmu.edu .

Is CMU compliant with NASA COI policy?

Yes. CMU's policy and processes are compliant with the Conflict of Interest Policy for Recipients of NASA Financial Assistance Awards. If you are asked about this by a collaborating institution for one of your research projects, you may direct them to this FAQ. Questions may also be directed to coi-compliance@andrew.cmu.edu .

Who Discloses and When?

What happens if a required disclosure or training is not completed?

When you receive a new award or a modification or supplement to an existing award, the Office of Sponsored Programs will verify that you have a complete and unexpired disclosure on file, and that you have also completed any project-specific requests to provide additional information about your financial interests or outside activities as they relate to that project.

If these have not been completed, you will be notified by ORIC and/or OSP. You will not be able to begin spending on the new award until your disclosures are completed and reviewed, and any necessary conflict of interest management plans have received all necessary approvals.

I'm a retired and/or Emeritus professor; do I still need to disclose?

If you are still engaged in CMU sponsored research post-retirement, you will need to continue to disclose. If not, you can alert ORIC via email to coi-compliance@andrew.cmu.edu and your disclosure request will be withdrawn.

What to Disclose

The value of my financial interests fluctuates. How often do I need to update this information?

You do not need to disclose ongoing fluctuations in the value of your previously disclosed SFIs more frequently than annually. Annual updates are sufficient in most cases. If a more recent update is needed to review or manage a specific conflict, ORIC will ask you to provide additional detail.

It's also not critical that you provide the value as of the date of disclosure, for something that fluctuates regularly like a stock holding. Providing values from e.g. a recent statement from your stockbroker is fine in most cases.

If I have a relationship that qualifies as both an SFI and an OA do I need to disclose it twice?

No. You only need to answer the questions about that interest once via SPARCS; this will satisfy both your COI and OA disclosure requirement for ORIC. The system will show you a list of all the kinds of relationship you can disclose. If you have multiple types of relationship with that entity, e.g. consulting payments that qualify as an SFI and also an unpaid board of directors role that qualifies as an OA, just check both types of interest from the list. You don't need to specify which is an SFI vs. an OA.

Is an unpaid role on a conference planning committee disclosable as an outside activity, and which category(-ies) of activity should it be disclosed as?

Yes, a role in planning a conference is generally a disclosable outside activity per the Outside Activity Guidelines, and should be disclosed. This is true whether the role is paid or unpaid, for a foreign or domestic conference, and whether or not you have a named title like Chair of the steering committee or Editor of the resulting proceedings publication.

If your work included selecting the contributions that became part of the proceedings, you should typically select both "Other Appointments" and "Editorial Services" as the disclosure types associated with this conference. But if you are not sure which disclosure type(s) to select based on your role, ORIC can advise. Please note that for each type you select, you will be asked to provide an approximate number of days spent on this activity in the past 12 months. See the relevant FAQ item for more details on how to report time commitments when they are split across multiple types of activity.

If I disclose a relationship with one entity that covers multiple types of activity (e.g., both editorial services and consulting for the same entity), I may only know the overall time commitment I made, and not exactly how much time I spent on each type of activity separately. How do I enter my time commitments?

It's most important that the overall time commitment associated with that entity be accurate to the best of your ability. Beyond that, it is fine to simply make your best estimate of how the time was split across multiple types of activity. For example, if you worked 10 days overall for that entity, you might estimate that 7 days were spent on consulting and 3 on editorial. You do not need to provide documentation about this split or any justification for how you arrived at the split. If during the review process a potential conflict of interest or commitment is discovered related to your disclosure and a more accurate breakdown of the time spent is needed at that point, ORIC and/or your department will follow up with you to request that information.

How far back do I need to disclose in SPARCS?

Almost all disclosure questions in SPARCS ask you to report information from the 12 months preceding the date you are making the disclosure. You do not need to disclose relationships/activities that have not existed in the past 12 months, and you may remove an item from your disclosures once it has been ended for more than 12 months.

There is one specific question in SPARCS related to U.S. government consulting work, such as Systems Engineering and Technical Assistance (SETA) contracts, that will ask you to include items from the past five years. For that question, items may be removed when they ended more than five years ago.

On occasion, CMU may respond to a solicitation, or negotiate a contract, that includes a different time frame. In those cases a member of ORIC's COI team will contact you to ask about any interests that may fall within that time frame that our usual 12-month period would not capture.