https://provost.ouhsc.edu/Conflict-of-Interest Parent Page: Conflict of Interest id: 23992 Active Page: COI in Research id: 23996

Research Requirements

Application of the Conflict of Interest Policy in Research

In addition to the Board of Regents Individual Conflicts of Interest Policy, all employees participating in research must meet additional disclosure and training requirements as outlined below.  

This additional training is for anyone who is currently or is proposed to be a Principal Investigator, Senior/Key Personnel, and/or anyone actively conducting research (basic, translational, or clinical) on sponsored research grant awards, including all trainees and personnel involved in reconciling or overseeing funds related to sponsored research grant awards.

Important note: This required training for research-related employees is in addition to the annual COI disclosure form and general COI training required every four (4) years for all OU Health Campus employees.

Required Training 

  1. Financial Conflict of Interest Training Module:  This is required every four (4) years for all employees participating in research as outlined above.
    • Instructions:
      •  Click here to access the training module website.
      • Login with your OU Health Campus credentials.
      • Complete training and print certificate.
      • If applicable, notify your ORA administrator through SoonerTrack that your training has been completed.
  2. Other Support Policy & Disclosure Requirements *Updated October 2025*: This is required for all employees participating in research as outlined above.  
    • Instructions:
      • Click here to access the training content in the Navex Disclosure Management system.
      • Login with your OU Health Campus credentials.
      • Click on Training: Other Support Policy & Disclosure Requirements- 2025 under the View Campaign tab.
      • After verifying your information, click Continue.
      • Read the information on the Overarching Introduction, click Next.
      • Read the information on the Other Support- 2025 page and answer the two questions at the end of the training, click Next. 
      •  Read the Acknowledgement page and check the I Agree box, click Review to advance to the final page.
      • Click Submit on the bottom of the page.
    • Detailed Instructions:
      • Click here to download a user guide with detailed instructions and screenshots.
    • Common Issues/ Troubleshooting:
      • If you are not able to access the training after logging in, please email the COI Office at COIHSC@ouhsc.edu.  It is likely you have not been assigned the training.  

What research is covered?

  • All federally funded research
  • All industry-sponsored research
  • Research sponsored by foundations or other organizations with COI terms and conditions
  • All research involving human participants and submitted to the IRB, regardless of funding source

Significant Financial Interest and PHS Policy

  • Federal regulations and the PHS FCOI Policy require disclosure of Significant Financial interests on an annual basis and when a new relationship or activity arises.  
  • Significant Financial Interests (SFIs) are defined as:
Nature of SFI
Threshold
Excluded (Do Not Disclose)
Compensation and/or other payments for service
Exceeds $5,000, when aggregated
Annual Compensation received is less than $5,000, as well as any compensation received for lectures, seminars, teaching engagements, or service on advisory committees or review panels relating to federal, state, or local government agencies, an institution of higher education as defined in 20 U.S.C. 1001(a), an academic teaching hospital, a medical center, or a research institute that is affiliated with an institution of higher education, and compensation received from OUHSC funds
Equity interests in a publicly-traded entity
Exceeds $5,000 when aggregated
Interests in any single entity valued at less than $5,000 as well as interests in any entity through personal retirement accounts and mutual funds
Equity interests in a non-publicly-traded entity
0 / Any
Interests in any entity through personal retirement accounts and mutual funds
Intellectual property rights and interests upon receipt of income related to such rights and interests
Exceeds $5,000
Royalties received from OUHSC funds, and unlicensed intellectual property that does not generate income
Sponsored or reimbursed travel
Exceeds $5,000
Travel administered through OUHSC funds, and travel reimbursed or sponsored by a federal, state, or local government agency, an institution of higher education as defined in 20 U.S.C. 1001(a), an academic teaching hospital, a medical center, or a research institute that is affiliated with an Institution of higher education. 

*Note that while these are the definitions required by regulations and the OUHSC Board of Regents policy, the sponsor, your unit, or your department may require more stringent disclosure thresholds.