COI Training Frequently Asked Questions (FAQs)

No, the policy and the federal regulations require that investigators are trained on institutional specific conflicts of interest policy. 

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.


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.    


There are several triggers to consider in determining whether a student – undergraduate or graduate – needs to be trained in conflict of interest:

  • Is the student participating in a sponsored research project?

    • Participation in research managed through Sponsored Programs is one trigger, whether or not the student is being paid from the project. 

    • Students who are conducting research as an independent study or senior design project for credit, but not as part of a sponsored project, would not require training.
  • Does the student’s role in the research meet the definition of “investigator”?

    • “Investigators” are those “responsible for the design, conduct or reporting of research” regardless of title.

      • Participation in taking measurements, collecting data or samples, conducting tests or performing tasks under the supervision of another do not usually rise to the definition of investigator.  Investigators would typically add analysis or interpretation of the data, extrapolate from observations, build models, and so on, thereby making an original contribution to the research.
    • Many undergraduates, or even high school participants, are involved in research but often their work is not sufficiently independent to trigger the definition of “investigator.”  One exception may be students funded on a sponsored project REU (Research Experience for Undergraduates) in which the REU application specifies that the student will have some independent responsibility for the research.  In such cases, students would be subject to the COI training requirement.

      • The National Council on Undergraduate Research offers this definition:  Undergraduate research is an inquiry or investigation conducted by an undergraduate student that makes an original intellectual or creative contribution to the discipline.
      • Note the intent in this definition to have students make an original contribution to the research.
    • Graduate students funded on a sponsored project and conducting research related to a thesis or dissertation would almost always meet the definition of “investigator” and hence should be trained in conflict of interest. 

    • Many other graduate students may be functioning independently in the design or conduct of a sponsored research project, or be involved in writing up and reporting the findings even if the research is not part of their dissertation or thesis.  COI training would be required in these cases as well.

Additional considerations about student involvement in research:

  • University policy provides protections for students involved in research funded by a faculty member’s company or consulting.  Please see the relevant sections of policy 13010 and the related form, “Research Agreement for Students and Postdoctoral Associates.”  Faculty members are required to disclose student involvement with their private business or consulting so that appropriate steps can be taken to inform the student about the potential risks, avenues for redress if needed, and the scope of work/research and any restrictions on publication of the findings.

  • Caution should be exercised if a class project appears to serve the interests of a faculty member’s outside company or consulting.  Disclosure of a faculty member’s interest in the class project is important so that the risks and benefits can be assessed and the appearance of using student labor for personal gain can be mitigated.  When possible, such a project may be better handled as part of a university sponsored project with the student supervised by another uninvolved faculty member.