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FAQs: Financial Conflict of Interest

I am not a Principal Investigator (PI) of a grant/proposal. Do I need to fill out the COI forms?

If you are an investigator, as defined by UH policy, then yes, you must fill out the forms, whether you are the PI or not.

Investigator - This policy applies to all academic staff members who fall under the definition of Investigator. Specifically, the project director or principal Investigator, and any other persons, regardless of title or position, who are responsible for the design, conduct, or reporting of research or educational activities funded or proposed for funding. Therefore, the policy can apply to collaborators, consultants, post-doctoral fellows, graduate students, and others who meet the threshold for responsibility.

The PI determines who meets this threshold for responsibility, however all individuals listed on the grant as key personnel would meet this criteria.

Do I need to disclose ALL of my financial interests, such as retirement accounts/mutual funds?

First of all, only those financial interests that may be related to your research/institutional responsibilities must be disclosed. Secondly, you will only need to disclose income from these retirement accounts/mutual funds if you have control of the investment decisions for the individual funds.

Should the Conflict of Interest forms be signed by the Chair and Dean prior to sending to the COI Office?

Yes. All forms require two levels of acknowledgement signature prior to uploading to RD2K or forwarding to the COI Office. In a few cases, such as with the Division of Research Centers/Institutes, different signatures would apply. Refer to this table. Contact the COI Office at or Penny Maher if you have a question regarding who should sign.

If I am PHS (Public Health Service) funded (such as NIH), do I need to take any additional COI training?

Yes, you are required to take additional COI training. The University uses the Collaborative Institutional Training Initiative (CITI) website. Instructions to the training can be found here (PDF).

My research is not funded. Do I need to fill out the COI forms?

No, the University's policy regarding Conflict of Interest only relates to research or educational activities that are funded or proposed for funding.

I filed a COI Certification and Disclosure form last year. Do I need to file another one this year?

Yes, you will need to resubmit your certification and disclosure form(s) for the current fiscal year, even if there have been no changes. If you would like a copy of your previous year's form for reference, please contact the COI Office at or Penny Maher.

Is there a way that we can submit all of our COI information electronically?

No, not currently, however, we are actively working toward the implementation of an online system.

Can I sign my form electronically?

Yes, you can save/print the completed form as a PDF document and sign it electronically. See instructions here (PDF).

Once I have completed the forms and they have been signed by the appropriate parties, how do I upload them to RD2K?

See instructions (Cougarnet credentials required) on how to upload a form to RD2K. Do not forget to click the "submit" button once you have uploaded them or they will never get to us. If you are having technical issues with RD2K, submit a technical support request.

I'm getting ready to scan and upload the conflict of interest forms to RD2K. Do I need to separate the forms and upload one as the certification form, one as the disclosure form and one for travel disclosure or can they all be uploaded as one entry?

Yes, you can upload the entire package of forms as one entry. You do not need to separate the forms and make multiple uploads.

I don't understand one (or more) of the questions on the forms. Where do I go for help?

We are aware that some of the wording on the forms may be unfamiliar. However, certain language must remain specific to the federal regulations at 42 CFR Part 50 and 45 CFR Part 94. Our office is here to help with any questions/concerns you may have. You can send an email to or contact Penny Maher.