For Researchers

Submit or update your Potential Outside Activity, Employment, Conflict of Interest, and Commitment Disclosure (AA-21) online through the Huron Conflict of Interest system

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Disclosure Requirements for Researchers

Note: The Office of Research reviews disclosures associated with employees and affiliates engaged in research.  UCF employees not engaged in research may also be required to disclose and should refer to the University Compliance & Ethics Office for additional information regarding those requirements.

Who needs to disclose?

All employees (faculty, staff, and students) engaged in university research must submit an online Potential Outside Activity, Employment, and Conflict of Interest and Commitment Disclosure (AA-21) through the Huron COI system.

Employees are identified as “engaged” in research through two mechanisms:

Huron proposal or award record: The individual is named as an FCOI investigator on a Huron proposal or award record.

Payroll Feed: The individual is paid on a sponsored research project.

In addition, an affiliate or any other person, regardless of title, position, or employment status, who is responsible for the design, conduct, or reporting of sponsored research is required to disclose. An affiliate is defined as a compensated or uncompensated subcontractor, subrecipient, consultant, or other third-party entity performing sponsored research services for the university under a written or verbal agreement.  Affiliate and subrecipient disclosure instructions can be found on the “For Subrecipient & Affiliates” page.

What is the FCOI Investigator field in Huron?

The Financial Conflict of Interest (FCOI) Investigator field in Huron is used to identify individuals on the sponsored project who are subject to the FCOI reporting requirements. UCF Policy 4-504.3 defines an FCOI Investigator as the project director or principal investigator, co-investigator, key personnel, and any other person, regardless of title, position, or employment status, who is responsible for the design, conduct, or reporting of sponsored research (DCR). The term includes key personnel, collaborators, or consultants who are responsible for DCR.

Huron proposal and award records contain a field to identify FCOI investigators on sponsored projects. This field drives many important functions and notifications within the Huron COI module.

How do I determine if an individual is responsible for DCR on my sponsored research project?

The principal investigator (PI) is responsible for making the determination. The PI should consider the individual’s responsibilities on the project and their level of independence in carrying out those responsibilities. Individuals in a position to significantly influence the structure/methodology of the research, independently execute the research plan, or who are accountable for reporting research results must be named on the Huron award record and identified with the FCOI Investigator flag.

What do I disclose?

Employees should refer to the Outside Activity, Financial Interest, and Potential Conflict Disclosure Matrix for guidance on what is required to be disclosed. The matrix displays red text for requirements specific to researchers.

When do I disclose?
Annual Disclosure

All employees engaged in research must submit an online Potential Outside Activity, Employment, and Conflict of Interest and Commitment Disclosure (AA-21) through Huron COI on an annual basis.

Required disclosers will receive a system-generated email from pca@ucf.edu when an annual disclosure is due. This typically occurs in early August of each year for continuing employees or at the time of hire for new employees.

New Activity Disclosure

All employees engaged in research must submit an update to their AA-21 through Huron COI in advance of committing to a new outside activity or financial interest subject to AA-21 reporting.

Newly acquired or discovered financial interest

All employees engaged in research must submit an update to their AA-21 through Huron COI within 30 days of acquiring or discovering (e.g. through purchase, marriage, or inheritance) financial interests subject to AA-21 reporting.

Project Specific Disclosures

Researchers flagged as an FCOI Investigator on a sponsored research award record will receive a project-specific disclosure request (Research Certification) at the time of award if either of the following conditions are met: 1) The investigator has not updated their AA-21 within the last 365 days or 2) The investigator has not previously been engaged in sponsored research at UCF.

Investigators applying for Institutional Review Board (IRB) approval, must disclose any potential financial interests related to the research in the appropriate field of the study record in the Huron IRB module. The IRB Office will forward the study record to the Office of Research Compliance for review (via the ancillary review function).

Why do I need to disclose?

Disclosure is required to ensure compliance with federal regulations, state statutes, and university regulations and policies.

Failure by an employee to comply may result in disciplinary action up to and including termination for just cause. In accordance with Florida Statutes Section 1012.977, any employee engaged in the design, conduct, or reporting of research who failed to disclose an outside activity related to their UCF area of expertise or financial interest with a foreign entity shall be suspended without pay pending the outcome of an investigation which shall not exceed 60 days. Upon conclusion of the investigation, the university may terminate the contract of the employee.

How do I disclose?

Annual disclosures, updated disclosures, and project-specific disclosures (Research Certifications) should be submitted through the Huron COI disclosure system. Users can access the system by selecting the link provided in system-generated email notifications or by clicking on the icon below:

 

What happens after I submit my disclosure?

After a researcher submits an AA-21 annual disclosure or update, the online form is routed to their supervisor, Office of Research Compliance (if a significant financial interest threshold is met), and to University Compliance & Ethics. If a potential conflict of interest is identified, the researcher will be contacted for additional information and/or next steps.

After a researcher submits a project-specific disclosure (Research Certification), the online form is routed to and reviewed by the Office of Research Compliance. If a potential conflict of interest is identified, the researcher will be contacted for additional information and/or next steps.

What is a Conflict of Interest in Research?

Conflicts of Interest in Research occur when the outside activities or financial interests of an Investigator (or those of the Investigator’s spouse and dependent children) could directly and significantly affect the integrity of UCF research.

Outside activities and financial interests that reach the significant financial interest (SFI) threshold are identified during the disclosure process and evaluated by Research Compliance to determine if they are related to the Investigator’s institutional responsibilities.

Significant Financial Interest (SFI) Thresholds

A significant financial interest (SFI) is defined as a financial interest consisting of one or more of the following interests of the investigator (and those of the investigator’s spouse and dependent children) that reasonably appear to be related to the investigator’s university responsibilities:

  • Publicly traded entity: If the value of any remuneration received from the entity in the 12 months preceding the disclosure and the value of any equity interest as of the date of disclosure, when aggregated, exceeds $5,000.

  • Non-publicly traded entity: If the value of any remuneration received from the entity in the 12 months preceding the disclosure, when aggregated exceeds $5,000, OR when the Investigator (or investigator’s spouse or dependent children) holds any equity interest.

  • Intellectual property rights and interests (e.g., patents, copyrights, trademarks): Upon receipt of income related to such rights and interests.

  • Sponsored or reimbursed travel: Travel greater than $5,000 that is paid on behalf of the investigator. (Note: Travel that is sponsored or reimbursed by a federal, state, or local government agency, or is funded through a sponsored contract or grant through the Office of Research is excluded.)

The term significant financial interest does not include the following:

  • Salary, royalties, or other remuneration paid by UCF

  • Income from seminars, lectures, or teaching engagements sponsored by a federal, state, or local government agency, an institution of higher education, an academic teaching hospital, a medical center, or a research institute that is affiliated with the university

  • Income from service on advisory committees, review panels for a federal, state, or local government agency, institution of higher education, an academic teaching hospital, medical center, or research institute affiliated with the university.

Determination of a Financial Conflict of Interest

A Financial Conflict of Interest (FCOI) is an SFI that could directly and significantly affect the design, conduct, or reporting of research. The Office of Research Compliance will escalate disclosures containing actual or potential conflicts of interest related to sponsored research to the Research Conflict of Interest Committee for review. The Research Conflict of Interest Committee will determine if a monitoring plan or other action is necessary.