Office of Research Integrity and Compliance

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].

CMU personnel working on sponsored research who meet the definition of Investigator  given in the CMU Guidelines 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.  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.

“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.

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 sparcs-help@andrew.cmu.edu, 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.  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 first Annual Certification.  Every year after that, you will receive an e-mail from SPARCS one month before your old Certification is due to expire, alerting you to submit a new one..

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 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.

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.