Requirements for the CMU Research Community
The COI Quick Reference Guide [PDF] will answer most questions about who needs to complete a certification and what needs to be disclosed.
Two regulatory standards guide CMU's COI policy.
- Investigators seeking or receiving sponsor funds (other than Public Health Service) are required to disclose Conflicts of Interests according to the standards set forth by the National Science Foundation (NSF).
- Investigators seeking or receiving funds from a Public Health Service agency (or other sponsors following PHS) are required to disclose Significant Financial Interests related to their Institutional Responsibilities. These terms have very specific definitions and are discussed at length in CMU's COI Guidelines [PDF] document and in the disclosure forms.
Additionally, the Software Engineering Institute (SEI) has its own set of contractually-mandated standards that apply to employees at SEI, as well as to researchers in other campus departments who collaborate on research with the SEI. Campus researchers who collaborate with the SEI are therefore subject to two sets of standards: the one that applies to their own research, and SEI's.
The National Robotics Engineering Center (NREC) also has its own set of requirements, guiding who must disclose. All NREC staff (with a few exceptions) must file an Annual Certification, regardless of whether they are directly involved in research. NREC staff follow the NSF disclosure standard by default, unless their funding sources require them to use the PHS standard.
For a high level overview of CMU's COI policy and process, please refer to the COI Quick Reference [PDF] document.
"Investigators" Need to Complete Certifications
Federal regulations and CMU policy require that Investigators file COI Certifications. Investigators will be assigned an Annual Certification every year via the SPARCS system. Some Investigators may additionally be assigned propsal-specific Research Certifications for certain projects on a case-by-case basis, as a result of ORIC's review of those proposals.
The term Investigator is defined by the regulations.
- PHS definition of Investigator: The Project Director, Principal Investigator, Co-Investigator(s) or any other person, regardless of title or position, who is responsible for design, conduct or reporting of research funded or proposed for funding. This includes key personnel identified in the grant application, progress report or other report submitted to the funding agency by the Institution.
- NSF and all other definition of Investigator: The Project Director, Principal Investigator, Co-Investigator(s) or any other person, regardless of title or position, who is responsible for design, conduct or reporting of research funded or proposed for funding.
To be considered an Investigator for the purpose of COI, an individual has a level of responsibility such that they can have a meaningful impact on the results of the research. This could include recording study data without quality control mechanisms, independently analyzing data, and serving as an author on publications. If an individual's role in the research is significant enough that they are specifically listed in a proposal for funding, they are considered to be an Investigator and should complete a Certification.
Certain staff at NREC may not meet the federal definition of an Investigator but will be assigned Annual Certifications nonetheless due to NREC's own requirements.
Complete Certifications in SPARCS
Investigators submit COI Annual Certifications and Research Certifications in SPARCS. Details on using SPARCS are on the SPARCS website.
In rare cases where SPARCS cannot be used because the Investigator does not yet have an Andrew ID to access SPARCS, a Certification may be submitted on paper using the Conflict of Interest Disclosure form [DOC]. In these cases, a SPARCS certification must still be submitted once the Investigator has an Andrew ID.