Carnegie Mellon University

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.

Investigators seeking or receiving sponsor funds 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.  Specific sponsors or agreements may include a broader requirement for who must disclose and what interests they must disclose.

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 all Investigators, 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. 

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 in CMU's COI Guidelines [PDF] as 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.

Certain staff at NREC and the SEI 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.  They may also submit an Update Certification at any point between Annual Certifications. 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.