Conduct of Research or Research: Any organized program of scientific inquiry that involves a systematic investigation designed to develop or contribute to generalizable knowledge that is performed at or under the auspices of the University, whether or not such Research is sponsor-funded. “Conduct of Research,” as used in this Policy, includes the design, development, testing, evaluation, conduct, reporting, review, or oversight of such program of scientific inquiry. By way of example, the Conduct of Research includes, but is not limited to, directing or serving as an Investigator, performing laboratory experiments, soliciting consent from research subjects, or making decisions related to the Research, such as eligibility of patients to participate in Research, analyzing or reporting Research data, or submitting manuscripts or abstracts related to the Research for publication. “Conduct of Research” as used in this Policy, includes, but is not limited to, basic and applied research, clinical research, research fellowships and training programs, and research-related activities in undergraduate and graduate education.
Consultant: An individual or firm that provides professional advice or services on a sponsored project for a fee, but is not a University employee.
Covered Individual: Any Investigator or Research Administrator.
- Investigator: Any person who is responsible for the design, conduct, or reporting of Research. This includes but is not limited to the Principal Investigator (PI), Co-PI, Co-Investigator, Project Director (PD), Co- PD, Senior/Key Personnel, and any other persons involved in the Conduct of Research, regardless of title or position, who are responsible for the design, conduct, or reporting of Research performed by or under the auspices of the University. This may include students, trainees, collaborators, volunteers, and Consultants if those individuals have some degree of independence in performing some aspect of design, conduct, or reporting of the Research. The term “Investigator” does not include individuals whose performance within the Research is purely ancillary or occurs solely under immediate supervision.
- With respect to clinical research, "Investigator" includes individuals who are directly involved in the research intervention or consenting or evaluation of human research subjects, but does not include hospital staff or office staff who provide only ancillary or intermittent care and do not make direct and significant contributions to the research data.
- For the purposes of compliance with this Policy, an individual’s position, title on the project, employment status (full or part-time), or percentage of effort devoted to the project do not factor into the definition of Investigator. The term “Investigator” is based upon the individual’s independence in the design, conduct, or reporting of the Research.
Equity Interest: Any stock or other ownership interest, or an entitlement to obtain any stock or ownership interests (e.g., stock options and warrants). The value of an Equity Interest is determined through reference to public prices or other reasonable measures of fair market value.
Family Member: A Covered Individual’s spouse or dependent children. For purposes of this Policy, a “spouse” includes a person to whom one is married, or a person with whom one lives together in the same residence and where each person shares responsibility for the other’s welfare and financial obligations.
Federally Funded: Any sponsored research activity where the source of funding is provided, either directly or through subaward to the University, from any federal agency.
Financial Conflict of Interest (FCOI): A Significant Financial Interest (SFI) or Significant Personal Interest (SPI) is considered to be a Financial Conflict of Interest (FCOI) under this Policy when the SFI or SPI is Related to, or can be perceived to be Related to, the Covered Individual’s Institutional Responsibilities.
Institutional Responsibilities: Institutional Responsibilities of Covered Individuals include research, scholarship, teaching and instruction, development and commercialization of research results, administrative service to the University, membership on institutional committees, and all other work and activities that the University considers in its review of an individual’s performance in the course and scope of his/her University employment or other obligations. A Covered Individual’s Institutional Responsibilities include any activities (a) performed as a University employee or a collaborator with or Consultant to the University; or (b) related to activities involving the Investigator’s professional expertise, such as teaching, administrative duties, clinical activities, Research (sponsored or unsponsored), federally funded project activities, service on University committees, professional participation on panels and review boards, including data and safety monitoring boards, and creation and presentation of scholarly work, etc., regardless of when and where the activities occur.
Institutional Review Committee (IRC): The IRC is a University-wide committee consisting of at least ten (10) voting members who are appointed by the Senior Vice President for Research:
- Three (3) faculty members from the Health Sciences
- One (1) faculty member from the College of Engineering
- Two (2) faculty members from the College of Science
- Four (4) faculty members from other academic units
Faculty members should be active researchers with an understanding of research practices and activities within their respective disciplines.
The IRC also includes non-voting, ex-officio members from the following units as necessary: Office for the Responsible Conduct of Research (ORCR), Technology Transfer Arizona (TTA), Office of Research and Contract Analysis (ORCA), Sponsored Projects Services (SPS), Office of the Human Subjects Protection Program (HSPP), Procurement and Contracting Services (PACS), and Office of the General Counsel (OGC). The committee may invite other non-voting, ad hoc members to assist in discussions and decisions as needed.
National Science Foundation (NSF): The NSF and any components of the NSF to which the authority involved may be delegated, including those federal sponsors that incorporate NSF general terms and conditions by reference into grant and contract terms and conditions for that funding agency.
Outside Interests: All Significant Personal Interests and Significant Financial Interests of a Covered Individual, or his/her Family Member (with respect to Investigators) or Relative (with respect to Research Administrators) that are not Excluded Interests, as such terms are defined in this Section.
- Significant Financial Interest (SFI): For purposes of this Policy, the definition of a “Significant Financial Interest” with respect to an Investigator differs from the definition applicable to a Research Administrator:
- Investigator SFIs: A SFI exists when any of the following interests are present with respect to the Investigator or his/her Family Member:
- Intellectual Property Interests: Has received income related to intellectual property rights or interests (e.g., as owner of a patent or copyright or as a licensee of such rights) except for those interests determined to be Investigator’s Excluded Interests, as outlined in paragraph 2, below; or
- With respect to any publicly traded entity: (i) Has received Remuneration from any publicly traded entity in the twelve months prior to disclosure; and/or (ii) has any Equity Interest in the publicly traded entity as of the date of disclosure and the combined total of all such Remuneration and Equity Interests exceeds $5,000 in value when aggregated; or
- With respect to any non-publicly traded entity: (i) Has received Remuneration from a non-publicly traded entity in the twelve months prior to a disclosure, and the value of all such Remuneration exceeds $5,000 when aggregated; or (ii) Holds any Equity Interest in a non-publicly traded entity, regardless of the percentage of equity or value.
- Investigators’ Excluded Interests: SFIs of an Investigator do not include the following interests, which do not need to be disclosed under this Policy:
- Salary, royalties, or other Remuneration paid by the University to a current University employee or appointee;
- Payments made by the University in exchange for the transfer of intellectual property rights assigned to the University and from agreements by the University to share any royalties related to such rights;
- Income from investment vehicles such as mutual funds and retirement accounts, as long as the Investigator does not directly control the investment decisions made by the investment managers within these funds or accounts; and
- Income from seminars, lectures, teaching engagements, or service on advisory committees or review panels sponsored by (i) a government agency (federal, state, or local); or (ii) an institution of higher education as defined at 20 USC § 1001(a); or (iii) an academic teaching hospital, medical center, or research institute that is affiliated with an institution of higher education.
- Research Administrator SFIs: A Significant Financial Interest (SFI) of a Research Administrator under this Policy means any pecuniary or proprietary interest held by the Research Administrator or his/her Relative in a Third-Party Organization, other than a “remote interest.” “Remote interests” are defined in the Arizona conflict of interest law (Arizona Revised Statutes A.R.S. § 38-502) and include the types of interests listed in paragraph 4 below, which do not need to be disclosed under this Policy.
- Research Administrators Excluded Interests:
- Non-salaried officer of a nonprofit corporation;
- Landlord or tenant of a contracting party;
- Attorney of a contracting party;
- Member of a nonprofit cooperative marketing association;
- Ownership of less than 3% of the shares of a for-profit corporation, provided the total annual income from stock dividend or other payments, including the value of stock dividends, from the corporation does not exceed 5% of the total annual income of such Research Administrator (or Relative) and any other payments made to him/her by the corporation do not exceed 5% percent of his/her total annual income; and
- Reimbursement received by a public officer or employee for actual and necessary expenses incurred in performance of official duty.
- Significant Personal Interest (SPI): A “Significant Personal Interest” is any managerial, professional, or fiduciary position held in any Third-Party Organization (e.g., as an officer, director, trustee, advisory board member, board of directors, or other managerial position), whether or not he or she is compensated.
Public Health Service (PHS): The U.S. Department of Health and Human Services (DHHS)and any components of the PHS to which the authority involved may be delegated, including the National Institutes of Health (NIH).
Related to or Relatedness: “Relatedness” is the condition in which it may reasonably appear that decisions made by the Covered Individual in the performance of his/her Institutional Responsibilities could directly and significantly affect the value of his/her Significant Financial Interests or be in conflict with Significant Personal Interests. Relatedness includes situations in which a Covered Individual’s Outside Interests would reasonably appear to affect, or to be affected by, the individual’s Research or other Institutional Responsibilities, as well as situations in which the Outside Interest involves an entity whose financial interests would reasonably appear to affect, or be affected by, the Covered Individual’s Conduct of Research or other Institutional Responsibilities. Examples in the context of Research are provided below. Relatedness is not a judgment on whether the Covered Individual would deliberately make choices in the Conduct of Research or the performance of his/her Institutional Responsibilities based on considerations related to his/her Significant Financial Interest or Significant Personal Interest. Rather, “Relatedness” refers to the condition in which it may reasonably appear that choices made in the Conduct of Research or other performance of the individual’s Institutional Responsibilities could be directly and significantly influenced by the existence of Outside Interests. For detailed information on relatedness as applied in IRC reviews, please visit the procedures for this policy.
Relative: For purposes of this Policy, "Relative" means a Research Administrator’s spouse, child, grandchild, parent, grandparent, brother or sister of the whole or half blood, and his/her spouses and the parent, brother, sister or child of a spouse (see ARS § 38-502). A “spouse” includes a person to whom one is married, or a person with whom one lives together in the same residence and where each person shares responsibility for the other’s welfare and financial obligations.
Remuneration: The aggregate amount of all loans, salary, and other payments for services not otherwise identified as salary (e.g., consulting fees, honoraria, and paid authorship) received from a Third-Party Organization. For purposes of this Policy, Remuneration includes the value of any loans received from a Third-Party Organization, regardless of whether the lender is a for-profit or nonprofit entity.
- With respect to Investigators funded by PHS/NIH, the Remuneration subject to this Policy includes the value in the aggregate of all sponsored or reimbursed travel costs received by the Investigator from a Third-Party Organization (regardless of whether it is a for-profit or nonprofit entity) that is related to the Investigator’s Institutional Responsibilities, as set forth in PHS/NIH policy (42 CFR § 50.606(c)). An approximate value of travel Remuneration may be reported if the actual value is not known. Travel costs paid from a University account for budgeted travel related to sponsored projects or other work contracted for through the University are excluded from the definition of Remuneration for purposes of this Policy.
Research Administrator: Any individual employed by the University on a full-time or part-time basis whose responsibilities include participation in any manner in contracts or services related to research administration, research contracting, research compliance, responsible conduct of research, sponsored projects services, or technology transfer (whether at the University, college, department, or program level) and who are in a position to influence decisions or commit University resources in the performance of his/her Institutional Responsibilities. This term does not include (a) individuals whose responsibilities are purely clerical or are performed solely under immediate supervision; (b) employees of Purchasing and Contracting Services (who are subject to Procurement and Contracting Services policy number 1.4); or (c) senior-level “University Administrators” (who are subject to the Institutional Conflict of Interest policy).[1]
Senior/Key Personnel: Anyone (including but not limited to the PI or PD) identified as senior/key personnel in the grant application, contract proposal, contract, progress report, or any other report submitted to the sponsor or funding agency by the University.
Subrecipient: A party that receives a subaward or subcontract from the University under a University sponsored project and is accountable to the University for the use of the funds provided by the subaward.
Third-Party Organization: Any group, organization, or legal entity (e.g., partnership, firm, trust, joint venture, corporation, etc.) that is not part of the University or ABOR.
[1] Conflicts of interest related to purchasing transactions are to be disclosed and managed as set forth in the Purchasing Policy Manual. Conflicts of interest involving senior-level University Administrators are subject to the University’s Institutional Conflict of Interest policy. Guidance on of these policies and procedures is available at the Conflicts of Interest Office page on the Office for the Responsible Conduct of Research website.