Public Health Service Agencies / NIH 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/

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.

In general, here is how these changes affect the reporting process:

  1. New questions in paperwork required by the Office of Contracts and Grants (OCG) during proposal submission
  2. Educational training must occur for all PHS/NIH disclosers:
    • 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 mandatory educational training module is available through Skillport via the following link: Log in to MyCUInfo at http://mycuinfo.colorado.edu/.

    You must have either an Employee ID number (EIN) or a Person of Interest ID number (POI) in order to access this site. For information about these types of IDs please contact the Personnel Payroll Liaison (PPL) for the department with which you are affiliated.

    1) Click on top tab: CU Resources.
    2) Click on the Training tab on the left side of screen.
    3) Click on Start SkillSoft. Be patient; loading may be slow.
    4) Access the Catalog on the left side of screen.
    5) Open University of Colorado – Courses.
    6) Open the COI folder, and select CU:Conflict of Interest for NIH.
    7) Start the module by clicking the blue triangle.

  3. Disclosure (DEPA reporting) – income or equity is 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
    • Travel is now reportable. For PHS/NIH research personnel, all travel reimbursement or sponsored travel related to institutional responsibilities must be reported as significant financial interest (SFI). Exclusions from this requirement include travel that is reimbursed or sponsored by the University of Colorado; a federal, state, or local government agency; or another institution of higher education; an academic teaching hospital, medical center or research institute that is affiliated with an institution of higher education.Travel is to be reported via the DEPA form. Please update your DEPA report throughout the year for those travel occurrences that meet the PHS/NIH reporting requirements.
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