FAQs
To whom does the policy apply?
The Policy on Conflicts of Interest in Research and Technology Transfer applies to all Baylor University research personnel responsible for the design, conduct, or reporting of research and who are currently participating in, or submitting proposals to participate in, research funded by a) federal, state and/or local government agencies, b) commercial sponsors, and c) other organizations funding research at or on behalf of Baylor University. Principal Investigators of non-funded non-exempt research involving human or animal subjects also fall under this policy.
What is the definition of research personnel?
"Research Personnel" refers to the following: tenure/tenure track faculty, research faculty, research associates, post-doctoral research fellows, and others identified at the time of proposal submission as having potential for a conflict of interest related to a research activity that involves their University responsibilities. This includes all full-time, part-time, regular FTE, temporary, and contract research personnel and others acting on Baylor’s behalf in the performance of University-related research.
How do research personnel disclose?
All research personnel who are responsible for the design, conduct, or reporting of research must complete a disclosure form through Compliance and Research Administration (CARA) software. Disclosures need to be completed:
- At least annually
- At the time of submission for new funding.
- For non-funded proposals, at the time of submission of non-exempt human or animal protocols if conflicts of interest related to the research exist (Principal Investigators only) and the Principal Investigator has not made a disclosure within the past twelve months..
- Within 30 days of discovering or acquiring a new significant financial interest.
- A significant change to a previous disclosure
Failure to submit a disclosure may delay the submission of proposals or the release of research funding.
Conflict Disclosure and CITI Training only for Baylor faculty, staff, and students? What about practitioners working on the project that are not Baylor faculty?
BU policies concerning COI disclosure and CITI training only apply to BU faculty, staff, and students. External individuals must follow their own institutional policies regarding COI and training; however, there is no need for URAs to verify this. Federal award subrecipients verify their compliance with their institutional policies during the award process.
Are Outside Consultants required to complete the Conflict Disclosure and CITI Training?
Individuals external to Baylor do not fall under the policy and are not required to complete COI disclosure and training. If they are a subrecipient of a federal grant, the pre-award office will handle subrecipient requirements.
Is there a Baylor account for the CITI Training or will each school/college need to fund individually?
Baylor has a subscription that covers the entire university. There is no need for other accounts.
Are Baylor alumni able to access CITI Training utilizing their BU alumni email? How do we address alumni consultants?
A Baylor email address is required to register for and access CITI training. Any individual can choose Baylor University as their institution during the CITI registration process. Alumni who are not Baylor employees are treated as any other external individual.
Is there a central listing available that the URAs can access to verify status? If so, who is responsible for maintaining?
A central listing of individuals who have completed the COI disclosure, COI training, and/or RCR training is available in the “FY2022 Proposal Log” folder in the Sponsored Programs BOX folder. A Research Compliance Analyst, is responsible for upkeep. You can reach them at ResearchCOI@baylor.edu.
I don’t have federal funding.
Federal funding is not a requirement to fall under the BU policy for COI disclosure and CITI training. The policy applies to all Baylor University research personnel responsible for the design, conduct, or reporting of research and who are currently participating in, or submitting proposals to participate in, research funded by a) federal, state and/or local government agencies, b) commercial sponsors, and c) other organizations funding research at or on behalf of Baylor University. Principal Investigators of non-funded, non-exempt research involving human or animal subjects also fall under this policy. Baylor may also determine that personnel who do not explicitly meet the above definitions must follow the policy on a case-by-case basis.
This doesn’t apply to me because I don’t do human/animal subjects research.
Conducting human/animal subjects research is not a requirement to fall under the BU policy for COI disclosure and CITI training. The policy applies to all Baylor University research personnel responsible for the design, conduct, or reporting of research and who are currently participating in, or submitting proposals to participate in, research funded by a) federal, state and/or local government agencies, b) commercial sponsors, and c) other organizations funding research at or on behalf of Baylor University. Principal Investigators of non-funded, non-exempt research involving human or animal subjects also fall under this policy. Baylor may also determine that personnel who do not explicitly meet the above definitions must follow the policy on a case-by-case basis.
This doesn’t apply to me because I am not a “traditional” researcher.
The policy applies to all Baylor University research personnel responsible for the design, conduct, or reporting of research and who are currently participating in, or submitting proposals to participate in, research funded by a) federal, state and/or local government agencies, b) commercial sponsors, and c) other organizations funding research at or on behalf of Baylor University. Principal Investigators of non-funded, non-exempt research involving human or animal subjects also fall under this policy. Baylor may also determine that personnel who do not explicitly meet the above definitions must follow the policy on a case-by-case basis.
How does Baylor faculty, staff and students log into CITI to register for courses?
CITI registration instructions for first time users
How to affiliate your CITI profile with Baylor University
Access previous CITI Coursework or continue coursework already in progress by logging into the CITI Training site directly at www.citiprogram.org
