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FAQs: Financial Conflict of Interest

I am not a Principal Investigator (PI) of a grant/proposal and I do not have a human subjects or animal protocol. Do I need to submit a certification in the ICON system?

If you are an investigator, as defined by UH policy, then yes, you must submit a certification in ICON, whether you are the PI or not.

Investigator - 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 1 or proposed for funding. In addition, any research team member who indicates a financial interest related to the submission of a human or animal research protocol will be asked to complete a certification.

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

Compliance Guidance: Consider all personnel designing, conducting, or reporting research.

  • Principal investigators, co-investigators, and key personnel listed on a proposal always meet this threshold.
  • Other positions (for example: study coordinators, statisticians, and non-paid personnel) may also meet this threshold based on their role in the research.
  • If you are a collaborator or sub-recipient/subcontractor engaged in research awarded to another institution, certification under the UH policy is required.

I received an email from ICON indicating that my annual certification is due. Now what do I do?

Click on the link indicated in the email. It will take you to the ICON system. You will first need to login using your Cougarnet credentials, then follow the instructions here. There is also a training video of instructions here.

I received an email from ICON indicating that I need to submit a Research certification. What is that and why must I re-certify my annual submission?

The UH Policy on Conflict of Interest in Research and the federal regulations require that certifications and associated disclosures be actively updated on an annual basis and at the time of submission of a new proposal, but no later than, at time of funding. Prior to the release of funds, an investigator must certify all significant financial interests held by them or their immediate family members have been disclosed. Research certifications are triggered by a new award, or by indicating “yes” to having a financial interest associated with a human and/or animal research protocol.

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

You need to disclose ALL of your financial interests that may reasonably be related to your institutional responsibilities:

  • Institutional Responsibilities – Investigators' professional responsibilities on behalf of the Institution including, but not limited to, activities such as research, research consultation, teaching, professional practice, Institutional committee memberships, and service on panels such as Institutional Review Boards and Data Safety Monitoring Boards. All duties referred to in the University of Houston Faculty Handbook are considered Institutional Responsibilities.

There are some exclusions. For example, you will only need to disclose income from retirement accounts/mutual funds if you have control of the investment decisions for the individual funds.

Do I need to take any COI training?

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

My research is not funded. Do I need to submit a certification and disclosure?1

The University’s policy regarding Conflict of Interest primarily relates to research or educational activities that are funded or proposed for funding. However, any research team member who indicates a financial interest related to the submission of a human or animal research protocol will also be asked to complete a certification even if there is no associated funding.

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

Yes. You are required to submit a certification in ICON at least annually. If you have submitted an update within the last year, your next certification will be due one year from the latest submission. Once you have made an initial disclosure in ICON, the information will stay in the system. You will only be required to indicate if the information has changed and/or if you have new financial interests that need to be disclosed.

I don’t understand one (or more) of the questions on ICON – where do I go for help?

We are aware that some of the wording 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 telephone Penny Maher at 713-743-9255.

I am trying to submit my annual certification, however when I log into ICON, I cannot perform any function and I don’t understand what I am supposed to do.

You will need to contact the COI Office at, so that a certification can be set up in the system for you. Once the certification is set up, you will receive an email notification and you can then follow the instructions in question 2 above.

1 For the purpose of this policy, any gifts to a college or department with the intent of funding a research project are treated as a research award.