Parent Page: Research Administration id: 27325 Active Page: Research Requirements id: 27336

Research Requirements

Application of the Conflict of Interest Policy in Research

The PHS Conflict of Interest  policy requires training and disclosure before initiating and throughout the life a project.  Questions about whether a specific project falls under the PHS Conflict of Interest policy should be referred to ORA.

Below is general information related to the PHS Conflict of Interest policy.  More detailed information is available on these pages:

What research is covered?

  • All federally funded research
  • All industry-sponsored research
  • Research sponsored by foundations or other organizations with COI terms and conditions
  • All research involving human participants and submitted to the IRB, regardless of funding source

Who is required to follow this policy on the project?

Investigators must meet research-related COI training and disclosure requirements.  Investigator includes individuals responsible for the design, conduct, or reporting of research, regardless of position or title.  The Principal Investigator of a project is responsible for making the determination of what named personnel are Investigators. The Prime Investigator (PI) must designate all key personnel for proposals/projects.


  • Key Personnel are always considered Investigators by virtue of the definition of Key Personnel
  • Investigators may also include others (internal or external to OUHSC) who are independently responsible for research design, conduct, or reporting (i.e., individual(s) who have the authority to make independent decisions about the direction of the research and the subsequent conclusions about the results and/or are likely to be authors on manuscripts or to present research findings)
  • Investigators are not administrative personnel or individuals who perform routine, pre-defined, or incidental tasks related to the project
  • If an individual who is named on a project does not meet the definition of Investigator or key personnel, that individual is not required to disclose for the particular proposal.  However, general disclosure and training policies apply to everyone.

Training Requirements

Conflict of Interest in Research Training is required every four years for everyone involved in sponsored research whether considered key personnel or not. To complete training:

  • Click here to begin your training
  • Login with your OUHSC credentials
  • Complete training
  • Print Certificate

Disclosure Requirements

Disclosure is required prior to initiating a project, within 30 days of receiving a new significant financial interest, and at least annually, even if acknowledging no change.