Requirements for Investigators-Office of Research Integrity and Compliance - Carnegie Mellon University

Requirements for the CMU Research Community (Updated October 2014)

Effective October 21, 2014 CMU Investigators will use SPARCS COI to complete COI Certifications and Disclosures.  Use of SPARCS is being rolled-out over time. 

Please see the Roll-out Schedule [PDF] to determine when you should be using SPARCS.  By April 1, 2015, all Investigators will be submitting COI Annual Certifications and Research Certifications in SPARCS.

The COI Quick Reference Guide [PDF] will answer most questions about who needs to complete a certification and what needs to be disclosed.

Two regulatory standards guide CMU's COI policy.  

  1. Investigators seeking or receiving sponsor funds (other than Public Health Service) are required to disclose Conflicts of Interests according to the standards set forth by the National Science Foundation (NSF).  
  2. Investigators seeking or receiving funds from a Public Health Service agency (or other sponsors following PHS) are required to disclose Significant Financial Interests related to their Institutional Responsibilities.  These terms have very specific definitions and are discussed at length in CMU's COI Guidelines [PDF] document and in the disclosure forms.  

For a high level overview of CMU's COI policy and process, please refer to the COI Quick Reference [PDF] document.  The COI Decision Tree [PDF] is also helpful.  

"Investigators" need to Complete Annual and Research Certifications

Federal regulations and CMU policy require that Investigators file a COI Certification and Disclosure prior to submitting a proposal for funding.  Certifications must be updated at least annually. The term Investigator is defined by the regulations.

  • PHS definition of Investigator: The Project Director, Principal Investigator, Co-Investigator(s) or any other person, regardless of title or position, who is responsible for design, conduct or reporting of research funded or proposed for funding.   This includes key personnel identified in the grant application, progress report or other report submitted to the funding agency by the Institution.
  • NSF and all other definition of Investigator: The Project Director, Principal Investigator, Co-Investigator(s) or any other person, regardless of title or position, who is responsible for design, conduct or reporting of research funded or proposed for funding.   

To be considered an Investigator for the purpose of COI, an individual has a level of responsibility such that they can have a meaningful impact on the results of the research. This could include recording study data without quality control mechanisms, independently analyzing data, and serving as an author on publications.  If an individual's role in the research is significant enough that they are specifically listed in a proposal for funding, they are considered to be an Investigator and should complete a disclosure.

Complete Certifications in SPARCS

Effective October 21, 2014 CMU Investigators will begin using SPARCS COI to complete COI Certifications and Disclosures.  Use of SPARCS is being rolled-out over time college by college. Please see the Roll-out Schedule [PDF] to determine when you should be using SPARCS.

 By April 1, 2015, all Investigators will be submitting COI Annual Certifications and Research Certifications in SPARCS.  Details on using SPARCS are on the SPARCS website.  

If your college is not yet using SPARCS and you are not seeking or receiving PHS funding, you will need to complete a paper form to disclose situations where you believe you may have a Conflict of Interest.

  • Conflict of Interest Disclosure form [DOC]: Investigators seeking funding from all federal agencies (except Public Health Service Agencies), that think they do or may have a financial conflict of interest, must complete this prior to submitting a proposal for funding.