There have been many questions surrounding the COI requirements for NIH NRSA T-series training grants, for which I hope to provide clarification. Please see below.
Pre/Postdocs do not need to complete COI requirements (neither COI disclosure nor COI CITI Training) because they are not the listed PD/PI on these grants and are not considered PHS Investigators as they are not independently responsible for the design, conduct, or reporting of research funded by the NIH.
Mentors would need both the COI disclosure and COI CITI Training on file. They are faculty and would be considered PHS Investigators because they provide direct oversight of and education for the trainees, and are ultimately responsible for the design, conduct, or reporting of research funded by the NIH.
Per UChicago policy, UChicago faculty must complete the COI disclosure each fiscal year, so UChicago faculty, regardless of role, should have a COI disclosure on file for the current fiscal year.
Note: Faculty serving strictly as Advisory Committee Members do not need to complete COI CITI Training.
If you have questions, please do not hesitate to contact me.
Mallory A. Snyder, MPH, CSSGB
Director, Research Integrity
p: 773.702.4857 | f: 773.702.2142