The following employees must disclose potential Conflicts of Interest (outside activities, interests, and commitments in outside entities) through Potential Outside Activity, Employment, and Conflict of Interest and Commitment Disclosure (AA21) available at the Conflict of Interest & Commitment System in ARGIS:

  • Faculty
  • Post-Doctoral Associates/Researchers
  • Executive Service
  • Select individuals identified by the University in Positions of Trust (individuals with delegated authorized signature for UCF sponsored programs)
  • Sponsored project participants identified as responsible for the Design, Conduct, or Reporting of research proposals/awards (A&P, USPS, OPS, Adjunct Faculty, Courtesy Appointments, Visiting Scientists)

Examples of design, conduct, or reporting of research:

  • Design of projects to obtain research grants or awards
  • Serving as the Principal Investigator, Co-Investigator, or Project Director on a UCF research project, subcontract, collaboration, or consultation
  • Determination of enrollment and eligibility requirements for human research subjects
  • Presentation or publication of research data

Other employees engaging in research related business transactions through their outside entity and UCF, pursuant to FL statutes, may be required to disclose if they were not already activated in the Conflict of Interest & Commitment System.

When to REPORT

  • The COI reporting period is fromAugust 8th through August 7th, on an annual basis.  Notifications are sent via Potential Conflict Administration (PCA) email.


  • If a change occurs at any time during the annual COI reporting period, such change must be reported in an “Amendment”no later than 30 days of discovering, acquiring, or committing to a new financial interest or commitment.
  • If transferring from another institution to UCF, complete a conflict of interest disclosure at the time of sponsor application but no later than thirty (30) calendar days from the date of employment.  New employees are contacted via PCA email in accordance with Human Resources record updates.
  • Students are required to disclose when the Principal Investigator confirms the students are responsible for design, conduct, or reporting of research on projects funded by agencies using the Public Health Service regulations for financial conflict of interest reporting.

For more information See "Does Student Need to Disclose?"

Subrecipient & Affiliate Reporting

Subrecipients/Affiliates are responsible for disclosing significant financial interests that are directly related to their work being performed for UCF when funding is through sources compliant with PHS FCOI regulations. When the subrecipient investigator is unable to certify that it has a compliant financial conflict of interest policy as delineated in CFR 42 Parts 50 and 94, UCF Contracts and Grants personnel will request disclose of outside activity through a Subrecipient Disclosure Form at time of proposal submission/contract renewal.

Review of COI Disclosure AA-21 Form

Online disclosures are reviewed and approved by several reviewers including an employee’s direct supervisor, the Office of Research & Commercialization, and the University Compliance, Ethics, & Risk Office.

If any disclosure includes a Monitoring Plan and/or Request for Exemption it will also be reviewed and approved by the University Provost, President, Board of Trustees, and the Financial Conflict of Interest Committee.