For PHS/NIH research personnel, completion of the required educational training and DEPA reporting are both required in order to meet federal requirements.
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 the following website: http://www.hhs.gov/about/orgchart/
In general, here is how the new changes affect the reporting process:
- Disclosure: All faculty, and any other employee 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 and external professional activity that could compromise university decision making or duties. See the list of personnel categories that must disclose from the Conflicts of Interest and Commitment page or the Disclosure Form (DEPA) page.
- New questions in paperwork required by the Office of Contracts and Grants (OCG) during proposal submission
- Educational Training must occur for all PHS/NIH disclosers
AS OF 9/25/2014: The COI for NIH Researchers training module is now imbedded in the DEPA reporting process. Researchers who indicate on the DEPA disclosure form that they are involved with NIH projects will not be able to move forward on that form without having satisfied the training requirement. If the requirement has been met previously, the date of training will automatically populate on the DEPA disclosure form and the reporting process can continue.
- Prior to engaging in any grant or contract funded by the Public Health Service (including NIH)
- At least every four years after initial training
- When warranted by other circumstances, such as noncompliance
The following University of Colorado Boulder COIC lectures also satisfy the requirement. (Information and dates about these courses have been populated into the DEPA database):
- Responsible Conduct for Researchers refresher class of 1/16/13
- Responsible Conduct for Researchers class of 9/27/12
- Responsible Conduct for Researchers class of 10/14/13
- Responsible Conduct for Researchers class of 9/29/2014
4. Threshold Changes: Income or equity is now reportable if it meets or exceeds:
- $5,000, alone, in income/payments for service
- $5,000 for the AGGREGATED SUM of income and equity interest/ ownership received from a publicly traded company
- ANY equity interest received/ownership of a non-publicly traded company
5. Travel Reporting Requirements- see travel tab
Example of how NIH training appears during DEPA review:
DEPA Review for: Ima.Resperson
Home Department: Coop Inst Res/Envrm Sci - Dir
Conflict of Interest NIH-WEB MAR 12, 2013
NIH training is required every 4 years.