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The Basics for Employees, Students and Affiliated Persons of the University of Colorado Boulder campus

HOW does CU-Boulder identify conflicts of interest or commitment and how do I access the DEPA? 
The University requires faculty to submit an annual on-line Disclosure of External Professional Activities (DEPA). Information regarding conflicts of interest reporting for other University of Colorado campuses can be found on the Forms, Checklists, Contacts & Links tab to the right of this page.

WHO is required to submit the DEPA?
All faculty, and any other employee (regardless of job title/postion), or student with responsibility for the design, conduct or reporting of research are considered critical to the research process and must disclose any significant financial interest (SFI) and external professional activity that could compromise university decision making or duties.  Projects and protocols submitted to the Office of Grants and Contracts or to the IRB cannot receive approval until an annual DEPA is submitted, reviewed and approved.   It is not for each individual researcher to decide if he/she must report based on a belief that no conflicts exist.  ALL personnel listed in the groups below must report, as stipulated, in order for the institution to be in compliance with federal regulations. 

The following University of Colorado Boulder personnel required to submit an annual Disclosure of External Professional Activities (DEPA):

  • ALL Tenure track faculty (assistant, associate, full professor)
  • ALL Adjunct faculty (assistant, associate, full professor) and Visiting faculty
  • NOTE: Adjoint faculty DO NOT need to submit
  • ALL Research professors (assistant, associate, full)
  • ALL Research employees with "research" in the title (e.g. professional research assistants [PRA], senior professional research assistants, research associates, or senior research associates)
  • Museum associates
  • Librarians
  • Any KEY PERSONNEL involved in research who is supported in salary, supplies, space or other resources by grant funding. (This includes PIs, co-investigators, and may include coordinators, graduate students/students.)
  • Undergraduate students, Graduate students, Fellows-IF they are responsible for the design, conduct or reporting of research. Also see: Outside Employment by Graduate Students on RA Appointments, COI Section - http://www.colorado.edu/industry/sites/default/files/attached-files/Outside%20employment%20by%20Graduate%20Students%20on%20RA%20appointments.pdf
  • Volunteers and consultants-IF they are responsible for the design conduct or reporting of research. (Non-university employees such as collaborators, consultants and subcontractors may be allowed to submit disclosure from another institution, depending upon funding agency requirements.)
  • Staff who negotiate or execute research agreements on behalf of UCB, staffs of the Office of Contracts and Grants and the Technology Transfer Office, and members of research review committees
  • Note: Professional Exempt personnel (P.E.), Instructors (assistant, instructor, senior), Lecturers and Teaching Assistants DO NOT need to submit unless they are responsible for the design, conduct or reporting of research or negotiating or executing research related agreements on behalf of UCB. 

WHEN does the DEPA need to be submitted?
Between January 15 and March 31, as well as any time throughout the year if circumstances change.

How often should the DEPA be submitted? 
Annually, and updated within 30 days of a status change.

How can I prepare for reporting via the DEPA?
Click on the DISCLOSURE FORM (DEPA) tab to the right of this page,  then open the Sample Form to view the questions that are asked. For 97% of employees, this is a simple, short process that will take only a few minutes. For returning users, the last submission entered will remain accessible, for editing purposes, until the end of the calendar year. In January, the last entry from the previous year will move forward and can be edited, as needed, to provide a new annual report.

Why are there unique reporting requirements for PHS/NIH funded research personnel?
As of August 24, 2012, academic institutions are required to implement changes in some of the regulations governing Conflict of Interest reporting. These changes affect research personnel who receive funding from/are supported by Public Health Service (PHS) agencies, including, but not limited to, the National Institute of Health (NIH). An expanded list of agencies can be found at:http://www.hhs.gov/about/orgchart/. Also see the Public Health Services Agencies/NIH section of this website. 

What are the requirement specifics regarding department approval of self-authored instructional material?
A process has been adopted that addresses the real, potential or perceived conflict of interest that may arise in situations where self-authored instructional material is required/recommended for the author's course. Specifically, one of the DEPA questions will ask if the instructor has obtained departmental approval via the use of the Self-Authored Teaching Materials Approval Form. If you do not have approval, your DEPA status will not be in compliance until you do. The COIC office does not need a copy of the signed approval form. However, the approval information must be acknowledged in this DEPA reporting system and certified per the usual final step of submitting your DEPA report for review. Use of Self-Authored Instructional Material Approval Form 

Are there limits to receiving income/funding from outside of the university?
While the DEPA asks about outside income of $5,000.00 or greater, please see the following section for specific threshold information depending on funding source:  POLICIES AND PROCEDURES (tab to the right); Definitions; Significant Financial Interest (SFI).

Additional Important Links

In addition to the specific links listed here, please click on the Forms, Checklists, Contacts & Links tab on the right side of this page.

Outside consulting activities are govened by the APS regarding the 1/6th rule. Consulting Approval Form

Procurement Service Center (PSC) Conflict of Interest Evaluation Form  Use this form for purchasing requests that may involve a potential or actual conflict of interest, for example, arrangements involving a family member, your personal business, an unfair advantage to a specific vendor, etc.

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