Carnegie Mellon University

CMU has three 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 Annual Certifications once a year, and Research Certifications as requested by ORIC.  Some departments (such as NREC) may opt to have all staff complete Certifications as.  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.
When you receive a new award, the Office of Sponsored Programs will verify that you have a complete and unexpired Annual Certification on file, and that any Research Certifications specific to this project are also completed and reviewed.  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 Certifications are completed and reviewed, and any necessary conflict of interest management plans are in place.
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) or unless you have signed a campus collaboration agreement document to work on a project with the Software Engineering Institute.
All Investigators must complete COI Certifications 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. From within SPARCS, you can click on "My Inbox" to see all Certifications that are waiting for you to submit them.
If you have questions about using the SPARCS system 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 regardless of research funding. You will receive an e-mail from SPARCS letting you know that it’s time to complete your Annual 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.

Disclosures must be updated annually or when your significant financial interests change. This can be done easily by filing an Update Certification in SPARCS.  If you already have an Annual or Research Certification waiting for you to submit it, you can update your disclosures as part of that Certification instead of filing a separate Update Certification.

Staff in the Office of Research Integrity and Compliance (ORIC) may review your Certifications.  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 four 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.