Carnegie Mellon University

CMU has two policies related to conflict of interest which are available on CMU’s website.

Details are discussed in COI Guidelines

CMU faculty, staff and students working on sponsored research who meet the federal definition of Investigator need to complete a Certification.  Some departments (such as NREC) may opt to have all staff complete Certifications annually.  Some people who are not directly involved in research may still be asked by ORIC to complete Certifications as part of managing a potential conflict of interest.
An Investigator is the Project Director, Principal Investigator, Co-Investigator or any other person, who is responsible for design, conduct or reporting of research funded or proposed for funding.   

For research sponsored by a Public Health Service (PHS) agency the term Investigator also includes key personnel identified in the grant application, progress report or other report submitted to the funding agency by the Institution.  

If you are a master’s degree or undergraduate student, you generally do not need to disclose unless you have been asked to do so by your PI or the Office of Research Integrity and Compliance (ORIC).
All Investigators must complete a COI Certification via SPARCS.  You will receive an email from SPARCS alerting you when a proposal-specific Research Certification or your Annual Certification has been assigned to you; however, you can also log in to SPARCS and initiate your own Update Certification at any time.
If you have questions you may contact the SPARCS help desk by e-mailing, calling 412-268-3485, or looking for information on the ORIC website or SPARCS website.
In SPARCS a Certification is a set of questions you will answer, relating to your responsibilities at CMU and possible conflicts of interest. This Certification will be submitted, reviewed, and approved all within SPARCS. There are multiple types of Certifications: Annual, Research, and Updates.

A Disclosure is a set of questions you will answer within SPARCS, relating to your financial interests. Disclosures are embedded within Certifications. However, it may be useful to understand that the term "Disclosure" when used in SPARCS refers specifically to the financial information you have provided.
Annual Certifications must be completed by all Investigators with external funding.  Some business units, such as NREC or the Software Engineering Institute, require all staff to complete Annual Certifications. You will receive an e-mail from SPARCS letting you know that it’s time to do your Annual Certification.  

Research Certifications are made prior to submission of a proposal for funding.  When the Office of Sponsored Programs (OSP), via Sponsored Programs EXchange (SPEX), is made aware that you are submitting a proposal, you will receive an e-mail from SPARCS prompting you to complete a Research Certification.  This is a very quick process.

Disclosures must be updated annually or when your significant financial interests change. This can be done easily via SPARCS.

Staff in the Office of Research Integrity and Compliance (ORIC) will review all certifications that are flagged by SPARCS as having a Significant Financial Interest.  Disclosures indicating there is a potential conflict of interest may be shared with the Vice President for Research, the Conflict of Interest Committee, legal counsel or the Investigator’s department head or Dean.

PHS requires the university to disclose information to the funding agency and the public in limited situations.  If it is determined that a financial conflict of interest exists, CMU is required to provide certain information to the PHS funding agency. If it is determined that a financial conflict of interest exists, CMU is required to make certain information available to the public, upon request.

NSF requires the university to notify the NSF Office of General Counsel in the event a financial conflict of interest is identified and CMU finds that is it unable to appropriately manage the conflict.

Other sponsors' requirements vary, but are generally similar to the NSF's requirements.

Yes.  Training is embedded into SPARCS.  The first time you use the system, you will go through the training.  Thereafter, you will be automatically prompted to review the material at intervals.  Most Investigators must re-train every three years; SEI staff members or people involved in research collaborations with the SEI must re-train annually.  The SPARCS system will manage this for you, presenting the training material to you automatically when you are due to re-train.