The RCOI Office is required to review disclosures of financial interests from each person who is planning to participate in, or is participating in (1) a sponsored project and/or (2) a protocol submitted to the Office of the Institutional Review Board (OIRB) if that person is responsible for the design, conduct or reporting of the work. The Office of Sponsored Programs (OSP) personnel enter information about Responsible personnel into the proposal record in the Integrated Research Administration Portal (IRAP) system. Because of the connection of the IRAP system modules, the information is automatically transferred to the IRAP project case in RCOI.

​Type of Submission	RPL Required?​
​Original/New	​Yes (original RPL)
​Competing Continuation/Renewal	​Yes (original RPL)
​Transfer In	​Yes (original RPL)
​Change in PI	​Yes (original RPL)
​Resubmission	​Yes (original RPL)
​Amendment	​Only when there are changes in Responsible Personnel (revised RPL)
​Supplement	​Only when there are changes in Responsible Personnel (revised RPL)
​No Cost Extension	​Only when there are changes in Responsible Personnel (revised RPL)
​Revised Award	​Only when there are changes in Responsible Personnel (revised RPL)
​Transfer Out	​No
​Confidentiality Disclosure Agreement (CDA)	​No
​Project Master Agreement (PMA)	​No
Data Use Agreement (DUA)​	​No
​Teaming Agreement	​No
​Intergovernmental Personnel Agreement (IPA)	​No
Program Project Grants follow the same submission types as above but only submit RPL for subprojects​ ​
​Program Project Parent/Overall Project	​No
​Program Project Subprojects	​Yes

This form is required (1) for all new applications (submission types of Original/New; Competing Continuation/Renewal; Transfer In; Change in PI; or Resubmission) (original RPL) and (2) at any time there is a change in Responsible personnel on a sponsored project (revised RPL). Note that for program projects/center grants (P series grants) a separate RPL is required for each subproject. This form should not be submitted for the parent or overall project of a program project. If you have questions about whether your project is a program project/center grant, contact your OSP Officer for guidance.

The following submission types do NOT require a RPL to OSP: Transfer Out; Confidentiality Disclosure Agreement (CDA), Project Master Agreement (PMA), Data Use Agreement (DUA); Teaming Agreements; and Intergovernmental Personnel Agreement (IPA).

A RPL is required for the submission types listed above and any time there is a change in Responsible personnel on a sponsored project or on a related IRB protocol.

List all Responsible personnel on the sponsored project and any other Responsible personnel who will be named on related protocols submitted to the OIRB. For each individual, include the UAB BlazerID (for non-UAB personnel, list the affiliate organization), last name and first name (exactly as it is in Oracle) and project role.

Do Not list personnel that are Responsible at institutions that are subcontracts of your proposal and if UAB is a subcontract, there is no need to list the personnel at the Prime institution unless they are Responsible for part of the work done at UAB - please contact the RCOI if there are any questions.

Do Not list personnel associated with a service agreement that is processed through University Contracts.

Original RPL
Section I: When submitting an RPL with a checklist for an original new, change in PI, transfer in, resubmission or competing continuation check the box next to Original RPL. Please note that a RPL is required for each of these submission types. Enter the date that the checklist/RPL will be submitted to OSP. Include the PI's name as it is in Oracle and make sure to include the BlazerID. Enter in the Project Title. If completing the form for a subproject of a program, complete the subproject information section by including the title of the subproject and the subproject PI/PD last name, first name and BlazerID.

Section II: Check the box next to the appropriate approvals that are needed for the project.

Section III: This section is where personnel that are Responsible on the project are listed, including the PI. Make sure that the names for all personnel listed are consistent with how they are listed in Oracle and include BlazerIDs for all personnel who have them. For personnel that do not have BlazerIDs list their affiliate organization in the BlazerID column (Do Not List Personnel that are Responsible at institutions that are subcontract of your proposal and if UAB is a subcontract there is no need to list the personnel at the Prime institution unless they are Responsible for part of the work done at UAB - please contact RCOI if there are any questions. Do Not list personnel that are associated with a Service Agreement that will be processed through University Contracts.) The "Add/Remove from Project" column should not be completed for an original RPL.

Revised RPL
An RPL is not required at any other time unless there is a change in Responsible personnel. If the Responsible Personnel on a project need to be updated submit a Revised RPL to OSP. It is a good practice to check who is currently listed as Responsible by going into eReport and click on "CIRB Projects by Responsible Person" from the list.

Section I: Check the box next to Revised RPL and enter the date that the checklist/RPL will be submitted to OSP. List the PI's name as it is in Oracle and make sure to include the BlazerID. Enter in the OSP Assigned Number and the Project Title. If completing the form for a subproject of a program project, complete the subproject information section by including the title of the subproject and the subproject PI/PD last name, first name and BlazerID.

Section II: Check the box next to the appropriate approvals that are needed for the project.

Section III: Only list the personnel that are being added and removed as Responsible on the project. Make sure that the name for all personnel listed is consistent with the names in Oracle and include BlazerIDs for all personnel who have them. Make sure to check the add/remove boxes next to each person's name as appropriate.

A Change in PI and Resubmission submission to OSP generates a new OSP Assigned Number and therefore is a blank slate as far as personnel are concerned. Both of these RPL's should be marked as Original and should not list an OSP Assigned Number (the information on the related proposal is collected on the checklist). List only the personnel that are Responsible on the submission - there is no need to remove the old PI for the Change in PI submission or personnel that are not considered Responsible on the submission. Be sure to include any other responsible personnel who are/will be named on related protocols submitted to the OIRB. Do not check any of the add/remove boxes next to personnel names in Section III.

At UAB the BlazerID is a unique identifier. Including the BlazerID allows OSP and RCOI personnel the ability to determine which John A. Smith you are looking for. A BlazerID also gives us a unique identifier to use in case the name that is submitted does not exactly match what is in IRAP.

It is very important to include the individual’s official name as it is listed in Oracle. IRAP pulls UAB personnel from Oracle. In IRAP the only way for OSP or RCOI to add personnel to records is by searching for the individual using the last name. If the last name provided is not the consistent with the name in, OSP and RCOI cannot find the person. For example – You submit a RPL to OSP with the name Molly Moran (mmoran). OSP staff attempts to add Molly Moran to the record by looking up Moran under M; however, the system will not locate Molly under M because her legal last name (i.e. the name in Oracle) is Lerew.

Go to the UAB Directory. Click on the Authenticate button and log in with your BlazerID and password. Run a search, the results will include the BlazerID when you click on the name of the individual.

Please DO NOT assume that a person’s email address is their BlazerID, for many individuals it is not.

Often times an individual who is no longer working or a student at UAB will be listed on a RPL. If you know the individuals BlazerID, you may list it on the RPL, but please also include the individuals affiliate organization. A BlazerID will help us identify that we have added the correct individual and will ensure the correct training history is reflected in IRAP.

No. There is another process for identifying and reviewing personnel associated with subcontracts from UAB to other institutions.

Do Not list personnel on the RPL that are associated with a Service Agreement that is processed through University Contracts. RCOI does not consider these individuals to be involved in the design, conduct or reporting of the research. If you have any questions please contact RCOI.

Subinvestigator is a term used by the FDA that refers to investigators other than the PI. We often see this term used on WCG applications. This term should not be used when referring to the PI of a subcontract from UAB to another institution.

For new applications, all Responsible personnel listed on the RPL must have a current conflict of interest disclosure on file in order for the proposal to be submitted to the sponsor. If any Responsible personnel do not have a current disclosure on file and the External Interests project-case status is “No Disclosure” or “Awaiting Disclosure”, OSP cannot release the proposal submission to the sponsor.

All Responsible personnel must have a current disclosure on file AND have completed the Financial Conflict of Interest Training and the External Interests project-case status must be “Ok to Award” before OSP can release an award.

OSP does not check the status of a project-case prior to release of subsequent awards on active projects.
However, be aware that RCOI:
1. Will notify Grants Accounting to suspend activity on the related account if the responsible personnel added after the initial award have not disclosed and/or have not completed the required FCOI training within 5 business days after a second email notice from RCOI
OR
2. has the authority to suspend activity on the related grant account if the responsible personnel added after the initial award have not disclosed and/or have not completed the required FCOI training within a reasonable amount of time.

External Interest Project-Case Status	Status Explanation	Can OSP submit to sponsor?	Can OSP process award?	Can IRB submit to WIRB?
No Disclosure	There is no disclosure on file.  This is the default status when a case is initially established.	NO	NO	NO
Awaiting Disclosure	One or more Responsible personnel do not have a current disclosure on file.	NO	NO	NO
OK to Submit	All Responsible personnel have a current disclosure on file.  The status is only used on initial OSP submissions.  If a person is subsequently added who has not disclosed, the project-case status is not changed.	YES	NO	NO
Awaiting Training	All Responsible personnel have a current disclosure on file and any disclosed financial conflicts have been managed; however, one or more listed people do not have current Financial Interest training.	YES	NO	YES
OK to Award	Any disclosed financial conflicts have been managed.  The status is used only on new OSP submissions.  If a person is added before the award, the status can be changed to OK to Submit or Awaiting Training as appropriate, but if added after the award, the case status is not changed unless the added person does not have current training.  In this case, the status is changed to Awaiting Training even if the listed person has not yet disclosed.	YES	YES	YES
Not Active	The project is not in a pending/negotiating or funded status.	NO	NO	NO

The PI/PD, and anyone who is responsible for explaining the study, risk-benefit, and/or alternatives to potential participants in a clinical trial, is listed on the 1572 or device agreement and/or must complete a sponsor’s conflict of interest form and any other project personnel who is "responsible" for the design, conduct, or reporting of research are considered Responsible personnel.

When evaluating the other project personnel, (i.e. data manager, research pharmacist, radiologist, etc.), to determine whether that person is "Responsible", consider the following:

• the role, rather than the title, of those involved in research,
• the degree of independence with which those individuals work; and,
• the level of responsibility of individuals who, as part of an investigative team, will assist the PI/PD and make a direct and significant contribution to the data.

Note: See the RPL Instructions for definitions of design, conduct, reporting and research.

No; however, please be aware that personnel listed on the RPL will appear in the IRAP record as Key Personnel. This is not intended to be a reflection of Key Personnel as defined by the sponsor.,

You do not have to submit a new RPL unless (1) you have a change in Responsible personnel or (2) you would like to remove someone who is currently NOT responsible.

This information is stored in the Related Personnel Folder of the COI Project Case associated with the proposal. For information on how to view a project case in IRAP refer to the tips sheets located here: IRAP eReports (Please note BlazerID and password are required to view this webpage). All personnel currently associated with the project are listed in the section located ABOVE the "Additional Personnel Information" header. Additionally, an OSP eReport, Responsible Personnel Report, is available which provides a list of all personnel currently listed as Responsible on the project.

You should only include non-UAB personnel on the RPL if (1) you have confirmed that meet the definition of Responsible as defined in the instructions and (2) if they are NOT part of a subcontract from UAB to an outside institution.

Yes, please include ALL individuals working on the project who meet the definition of Responsible, unless those individuals are part of a subcontract/subaward from UAB to another institution. We have processes in place for non-UAB personnel to disclose Financial Interests and complete Financial Conflict of Interest Training.

o Note that a volunteer appointment should be obtained for the investigator prior to submitting the RPL. Provide the investigator’s It would be helpful if you could include their full legal name and where they work. You will may be contacted for additional contact information for the individual, such as a phone number and email address. This information is used by RCOI to contact the individual to collect disclosures and provide direction on how to complete Financial Conflict of Interest Training.

Please contact the IRB (irb@uab.edu) as the process for removing personnel may depend on the type of IRB submission

The IRB has a document that can help you determine if someone should be listed as responsible. Click Here