Where can I find CMU’s policy on conflict of interest?
CMU has three policies related to conflict of interest which are available on CMU’s website.
- Conflict of Interest and Commitment
- Compliance with Financial Conflict of Interest Requirements
- Organizational Conflict of Interest in Research
Details are discussed in COI Guidelines [PDF].
Who is required to complete a conflict of interest Certification?
What happens if a conflict of interest Certification is not completed?
How do I know if I'm an Investigator and required to complete a COI Certification?
“Investigator” means the Project Director (PD), Principal Investigator (PI), Co-Investigator or any other person, regardless of title or position, who is responsible for design, conduct or reporting of sponsored research, including research that is funded or proposed for funding. This includes all key personnel identified in a funding application, progress report or other report submitted by CMU to a funder. It also includes all personnel identified in the SPARCS proposal by name.
If an individual’s role in the research is significant enough that they are specifically named in a proposal for funding, CMU considers the individual to be an Investigator as defined above and the individual should complete a certification.
If an individual’s role changes during the course of a project or after a proposal has been submitted so that they would then be considered an Investigator, they are required to submit a certification at that time.
How do I complete a COI Certification?
Who can help me if I have questions about completing a Certification?
What is the difference between a Certification and a Disclosure?
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.
When do I need to file a Certification?
Research Certifications are initiated by ORIC for a limited subset of proposals that are identified by ORIC as having the potential for conflict of interest. In these cases, ORIC will assign you to complete a Research Certification and you will receive an e-mail from SPARCS. Being asked to complete a Research Certification does not mean that you definitely have a conflict of interest or that the conflict of interest will require a management plan; it only means that ORIC needs more information.
What if my information changes after I file my disclosure?
Disclosures must be updated annually or when your significant financial interests change. This can be done by filing an Update Certification in SPARCS. If you already have an Annual or Research Certification in process, you can update your disclosures as part of that Certification instead of filing a separate Update Certification.
Is there mandatory training?
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 two 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 your current training is getting close to expiration.