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Office of Research & Sponsored Programs

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Conflict of Interest

Training & Resources

DU Policy requires that all investigators on projects, regardless of funding or no funding, must complete conflict of interest training at least every four years.

Definition: An "investigator" is defined as the Principal Investigator, project director, and any other person, regardless of title or position, who is responsible for the design, conduct, or reporting of research funded by the PHS, including collaborators and consultants.

As part of the revised PHS regulations, the federal government has mandated conflict of interest training for all investigators on projects funded or proposed for funding by PHS agencies, including NIH and NSF.

What if my project is not funded?

Investigators who do not work on any PHS-funded projects need to complete COI training if they:

  • Are planning to submit a proposal through the Office of Sponsored Programs for funding from a non-PHS source; or
  • Are an investigator on an externally-funded research project not funded by an agency of the Public Health Service; or
  • Have disclosed outside financial interest on their University Faculty/Research COI disclosure form; or
  • Have been directed by their department chair or dean to complete COI training
Mandatory Training: CITI

The University of Denver utilizes the Collaborative Initiative Training Institute (CITI) Program ( for investigators who are participating, or are planning to participate, in PHS-funded or non-funded research.

CITI is an online training program that offers training modules in COI and other areas, including human subjects protection, animal care and use, biosafety, responsible conduct of research, etc. 

This training must be completed prior to initial receipt of funds, or project initiation if unfunded, and must be renewed every four years. 

For more information, please go to the appropriate page below:

IRB CITI Training


IBC CITI Training

Steps for Completing COI Training

A complete list of the training modules on conflict on interest will be provided after completing the following five steps.

After you have registered in the CITI Program and are affiliated with the University of Denver, you will need to log into CITI using your username and password.

Step 1:  On the CITI home screen, under "Institutional Courses," select "University of Denver View Courses" 

Step 2:  Scroll down to the bottom of the screen and select "Add a Course" 

Step 3:  Under Question 1, select "Conflict of Interest" and then select "Yes"

Step 4:  Select "Start Now" on the "Conflicts of Interest" course under "Courses Ready to Begin." All of the modules associated with the COI curriculum will be listed and you may select a module to begin.

Once you have successfully completed CITI registration and finished the modules in a selected curriculum, a completion report will be available to document your training. It is strongly recommended you save a copy of this report for your records. The DU CITI Administrators are able to verify all training profiles for individuals that are affiliated with DU in the CITI program.

Quick Links

CITI Program

NIH Federal Register Notice - Issuance of the Final Rule on Financial Conflict of Interest Regulations

Notice of NIH Improving the Financial Conflict of Interest (FCI) Module for Submission of Financial Conflict of Interest Reports to the NIH

NIH Financial Conflict of Interest Frequently Asked Questions, Section L. Training Requirements