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
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?
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.
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 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.
Who will see the information I disclose?
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.