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 were 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, the following changes went into effect:
- 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 during proposal submission in paperwork required by the Office of Contracts and Grants (OCG)
- Thresholds (limits) and criteria of what is reportable were revised. See Policies & Procedures: Definitions: Significant Financial Interest
- Requirement to specifically report travel separately on the disclosure form. See Travel.
- 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.
Note: The University of Colorado Boulder COIC video tutorial for NIH/PHS researchers is embedded into the DEPA reporting process. If the NIH/PHS COI training requirement has been met, the date of training will automatically populate on the DEPA disclosure form and the reporting process can continue. NIH/PHS researchers who have not satisfied the training requirement will be directed to follow a link to the training module where they can view the informational content and click to certify completion. Once completed, researchers can easily return to the DEPA reporting form so that it, too, can be completed. An approved COIC reporting status for NIH/PHS researchers is contingent upon the training requirement being satisfied.