Training is embedded in SPARCS COI and will be automatically required the first time that a new user completes a Certification. SPARCS COI keeps track of when training is due next (every four years for most Investigators, or annually for SEI employees or others who collaborate on SEI research) and will present training again when the old training is close to expiration.
Subcontractors and consultants on PHS-funded research must complete training as well, unless their institution is certified as PHS-compliant in the FDP Clearinghouse. Training documentation from their home institution may be sufficient; this is reviewed on a case by case basis. If no other acceptable training documentation is provided, such collaborators will be required to complete the NIH's FCOI training module and provide a completion certificate.
In the event it is determined that an Investigator has failed to comply with CMU's COI requirements, additional training may be required.