Disclosure of External Professional Activities (DEPA) Form

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

Proposals

• 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. 

Reminder Regarding PHS/NIH Projects

PHS/NIH projects require the researcher to be current with PHS/NIH training, required every four (4) years. Disclosers must indicate PHS/NIH funding on the DEPA Form in order to access the training module, and then check a box on the form indicating their completion.