Effective August 10, 2012, Virginia Tech implemented the new provisions of the Individual Conflicts of Interest policy 13010 which requires all investigators to complete initial and periodic training on Conflicts of Interest that includes informing investigators of the new regulations, the Institution’s FCOI policy, and of the Investigator’s disclosure responsibilities that meet or exceed the regulatory requirements.
Target Audience: Individuals required to complete training include, but may not be limited to: principal investigators, co-investigators, project directors, postdoctoral associates, graduate students and any other person deemed responsible for the design, conduct, or reporting of research. For the purposes of the Individual Conflicts of Interest Policy 13010, research includes outreach and service awards if there is a research component to the project.
All investigators with existing awards will need to be trained; see special requirements for Public Health Service awards below. As of August 10, 2012, investigators for all other awards must be trained within 30 days of project start-up.
Public Health Service (includes NIH, CDC, and more)
Federal regulations require all Public Health Service (PHS) investigators to complete training prior to expending funds; therefore, all PHS awards will be held until all individuals named in the proposal are trained. For all current, active PHS awards, investigators should be trained as soon as possible. All investigators with pending PHS proposals will need to be trained before award setup. Anyone added to PHS projects after award setup will have 30 days to complete the training. No work should be performed on the PHS project until training has been completed. Research administrators who support faculty members in proposal development or award management are encouraged to attend.
Initial and periodic training concerning applicable university policies and state and federal law and the investigator’s responsibilities for disclosure is required for all faculty engaged in sponsored research.
Retraining related to conflict of interest is required every four years and/or whenever there is significant change in university policy related to investigator responsibilities. Any investigator found to be in non-compliance with disclosure requirements will also be required to complete immediate training.
The Office of the Vice President for Research and Innovation (OVPRI) has established the following options for satisfying the new PHS requirement:
Face-to-Face and Synchronous Online Instruction
Individuals can register for face-to-face sessions through www.training.vt.edu. Login in using your VT PID and password and select "view by alpha" and scroll down to the courses whose titles start with “OVPR.” Click on the course titled "OVPR: Individual Conflicts of Interest and Commitment" and select the preferred session date/time. You will receive an email confirmation of enrollment.
Face-to-face sessions will be offered monthly through out the semester and as needed thereafter. These sessions will also include a live online option if you are not able to attend in person.
For questions about courses or enrollment, please contact Quinn Steen at email@example.com.
Asynchronous Online Training (CITI course)
Individuals can access an asynchronous on-line course created by the Office of Research and Innovation and maintained by the Collaborative Institutional Training Initiative (CITI), a nationally-recognized source for research-related training. After the learners complete and pass the appropriate modules, they will be able to print a completion report.
Failure to comply with this policy by any required participants within the specified time frame may result in freezing the account of the project supporting these personnel.
For more information:
- Technical issues regarding content delivered on the CITI website should be addressed to firstname.lastname@example.org or to 305-243-7970.
- Questions regarding COI training requirements should be addressed to email@example.com or 540-231-2336.
Research Integrity Training Tracking System
The Research Integrity Training Tracking System is available so that principal investigators and department staff, who have authorization, can view the training status of those required to complete responsible conduct of research or conflict of interest training.
Public Health Service (PHS) investigators can also submit their required travel disclosures via this system. To learn more about the travel disclosure required for PHS (NIH, CDC, etc.) investigators please go to the disclosure section.
This system will allow you to view:
- Individuals who have been added through payroll to a grant level sponsored project associated with your organization and is required to complete training
- Individual RCR and COI training status
- Training notification e-mails that were sent to the individual
- Individuals within your organization who have been trained in RCR or COI but are not currently on a sponsored project
The link to the system is https://secure.research.vt.edu/rcr/ (requires PID/Password).
Learn more about conflict of interest:
- Policy 13010 Individual Conflicts of Interest and Commitment
- NIH Web-based Tutorial on Financial Conflict of Interest
- Commonwealth of Virginia Conflict of Interest Website
- Faculty Handbook, Chapter 2, Conflicts of Interest and Commitment
- Faculty Handbook, Chapter 3, Imposition of a Severe Sanction or Dismissal for Cause
- Graduate Catalog, Policy on Additional Employment for Students Holding a Graduate Assistantship Employment
- Policy 4070, Additional /Outside Employment Policy for Salaried Classified and University Staff
- Policy 5000, University Facilities Usage and Event Approval
- Policy 13000, Policy on Intellectual Property
- Standards of Conduct and Ethics, Virginia Tech Purchasing Department