On the CU Boulder campus, annual online reporting of conflicts of interest and commitment occurs by submitting a Disclosure of External Professional Activities (DEPA).
The DEPA must be submitted annually between January 15 and March 31, and updates must be made within thirty (30) days of having something new to disclose.
All faculty, and any other employee (regardless of job title) or student with responsibility for the purpose, design, conduct or reporting of research are considered critical to the research process and must disclose any significant financial interest (SFI) and/or 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 must report, as stipulated, in order for the institution to be in compliance with federal regulations.
The disclosure process
Am I required to submit the Disclosure of External Professional Activities (DEPA)?
All faculty and any other employee or student with responsibility for the purpose, design, conduct or reporting of research are considered essential to the research process and must disclose any significant financial interest and external professional activity that could compromise or appear to compromise their judgment in performing their university duties or responsibilities. It is not for each individual researcher to decide if he/she must report based on a belief that no conflicts exist.
All faculty includes Tenured and Tenure-track faculty; Adjunct, Visiting, and Research faculty; retired faculty if engaged in research activities at CU Boulder; Professional Research Assistants, Research Associates, and Research Assistants; and Instructors. TAs, Lecturers and Adjoint Faculty typically do not need to submit the DEPA unless they are engaged in research activities. The disclosure requirement applies to full time and proportional appointments. Non-university employees such as collaborators, consultants, subcontractors, and volunteers may be required to submit the DEPA or to certify disclosure at another institution, depending upon funding agency requirements.
If you are engaged in one or more of the following activities, you are required to submit the DEPA:
- Directing, overseeing, or supervising the research process and/or research personnel
- Participating in theory development and testing
- Participating in the design and development of research protocols, experiments, tests, or other means of data collection
- Participating in sample design and selection
- Participating in the collection or analysis of data or the reporting of results
- Enrolling human subjects or participating in the informed consent process
- Intervening with human subjects by performing research procedures or manipulating the environment for research purposes
- Having access to personally identifiable study data
If you are engaged in only the following activities, you are not required to submit the DEPA:
- Performing data entry or statistical analysis on data sets without involvement in research design, sample selection, data collection, or reporting of results
- Participating in the recruitment of research subjects without any involvement in enrollment
- Interacting with research subjects without performing a procedure or intervention for research purposes
- Participating in the acquisition, monitoring, and maintenance of materials, supplies, and equipment without engaging in their use for research purposes
- Performing language translation of research-related documents, including survey instruments
- Hiring and training research personnel
In addition, the following groups are required to submit the DEPA:
- Librarians and Museum Associates and Fellows
- Research Committee Members (i.e., IRB members, IACUC members and/or other research review committees)
- Staff who negotiate or execute research agreements on behalf of CU Boulder: Area/Program Administrators, Office of Contracts and Grants staff members, and Venture Partners at CU Boulder staff members
- Office of Research Integrity staff members
Disclosure of External Professional Activities (DEPA) Form
To submit a DEPA, follow the instructions below.
- Instructions on how to fill out and submit the new DEPA form are included within the COI PI InfoEd Guide.
- Learn what's changed in the DEPA form for 2022.
- If you would like to preview the online DEPA form, click here: Sample DEPA Form
- Instructions on how to navigate to a previous DEPA form submission are located here.
Employees and Persons of Interest (POIs)
What do I need to disclose?
You need to disclose all significant interests held by you or a close family member related to or that reasonably appear to be related to your institutional responsibilities:
- External affiliations, activities, & appointments
- Positions, paid or unpaid
- Board membership, paid or unpaid
- Ownership interests
- Equity, stock, stock options in a publicly traded entity valued at more than $5,000 or in a non-publicly traded entity of any value
- External consulting activities and other outside work
- any service that is 1) related to your professional expertise in your university position, 2) provided to an external entity, 3) for remuneration (monetary) or other compensation greater than $5,000 from a single entity over the past 12 months, 4) including but not limited to advising; conducting research or analysis; writing reports; delivering presentations or training; contributing to or managing projects; designing, developing or producing products or services; providing clinical services
- In-kind contributions with an associated time commitment. This includes research collaborations with an entity, organization, and/or institution other than a U.S. institution of higher education from which you received monetary or non-monetary value (including free or subsidized space, laboratories, equipment, or materials; other in-kind contributions such as support services and visiting researchers or personnel) or a foreign research collaboration for any purpose. A research collaboration includes one or more of the following:
- Collecting, sharing, or analyzing non-public data
- Designing, fabricating, improving, or testing equipment together
- Contributions to writing or revising a manuscript with the intent to publish
- Traveling in support of the above actions
- Foreign activities of any kind, including research collaborations
- Reimbursed or sponsored travel
- To a U.S. destination valued at more than $2,500 when aggregated per entity over the previous 12 months
- To a foreign destination of any value
- Intellectual property
- Licensing or royalty income
- Foreign talent recruitment program participation
What do I not need to disclose?
You do not need to disclose the following:
- A personal or financial interest unrelated to your institutional responsibilities
- A financial interest that does not exceed the thresholds
- A U.S.-based research collaboration in which no monetary or non-monetary value is received from an outside entity, institution, or organization
- Salary, royalties, or other remuneration paid by the university if you are currently employed or otherwise appointed by the university, including intellectual property rights assigned to the university and agreements to share in royalties related to such rights
- Income from investment vehicles, such as mutual funds and retirement accounts, as long as you do not directly control the investment decisions made in these vehicles.
- Income from seminars, lectures, or teaching engagements sponsored by a U.S. federal, state, or local government agency; a U.S. institution of higher education as defined at 20 U.S.C. 1001(a); a U.S. academic teaching hospital, medical center, or a research institute that is affiliated with a U.S. institution of higher education
- Income from service on advisory committees or review panels for a U.S. federal, state, or local government agency; a U.S. institution of higher education as defined at 20 U.S.C. 1001(a); a U.S. academic teaching hospital, medical center, or a research institute that is affiliated with a U.S. institution of higher education
- Travel that is reimbursed or sponsored by the university; a U.S. federal, state, or local government agency; another U.S. institution of higher education; a U.S. academic teaching hospital, medical center, or research institute that is affiliated with a U.S. institution of higher education
The primary DEPA reporting period is January 15—March 31. Updates are required within thirty (30) days of a change in a previously disclosed interest or activity or having something new to disclose. New employees must submit a DEPA within thirty (30) days of their start date.
Between January 1—April 30, 2022:
- Having a current DEPA (within one year of the date of the proposal submission date) on file will meet the DEPA requirement for proposal submission.
- Award monies will not be released unless either the PI's DEPA has been reviewed with no conflict within the last 12 months of the date of award acceptance, or a 2022 DEPA form has been submitted and reviewed (or is under review) with COIC authorization that funding can move forward.
Beginning May 1, 2022:
- PIs must have a 2022 disclosure that at least is in a submitted status before the proposal can be submitted.
- Award monies will be released only if PIs have a 2022 DEPA Form submitted and reviewed (or under review) with COIC authorization that funding can move forward.
If the last DEPA filed is older than twelve (12) months, then disclosers must submit a 2022 DEPA before proposal submission.
It is the responsibility of PIs to ensure that all personnel involved in the design, conduct or reporting of research have met the DEPA requirements.
For researchers with MOUs requiring Monitoring Reports, submission is due at the time of the DEPA submission. Visit the Policy, Forms & Useful Links page for the Monitoring Form and additional information.
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